BZ

BZ schema crypto-v2.0.0 trajectory: not yet assessedprohibitedoverlaps: FIM

Last updated 2026-10-18 · 8 categories · 20 sourced findings · 15 sources in the cumulative register

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Jurisdiction lead brief

Standing brief, as of 18 October 2026.

Lead Signal

Belize digital-asset licensing regime passed a structural threshold on 1 January 2026, when the statutory prohibition under section 81 of the Financial Services Commission Act, 2023 on the Commission issuing licences for specified virtual-asset activities expired. That prohibition had barred licensing of such activities until 31 December 2025, and its lapse opened the gateway for the Financial Services Commission (Digital Asset Services Licensing) Regulations, 2025, made under S.I. No. 162 of 2025, to function as the operative licensing framework. Regulation 4(1) of those Regulations prohibits carrying on digital-asset services without a licence from the Commission, and regulation 4(2) makes contravention an offence; this is a binding, in-force requirement as of the Regulations 30 December 2025 commencement. The Regulations are, however, explicitly temporary: regulation 12 provides that they expire on the entry into force of the Financial Services Commission (Amendment) Act, 2026, with regulation 13 preserving existing licences until their own stated expiry. Belize digital-asset licensing framework is therefore best described as a functioning but time-limited gateway, operative today, due to be superseded once the Amendment Act commences, with the content and commencement date of that Amendment Act not independently verified this cycle.

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Belize does not operate a VASP licensing regime. Instead, the <cite index="74-11">operation of VASPs is prohibited until December 31, 2025, by virtue of s.81 (3) of the FSCA</cite> (Financial Services Commission Act, No. 8 of 2023). The <cite index="94-5">Belize has established measures for non-compliance with the prohibition</cite>, and the <cite index="74-9">FSC is the statutory body established in Belize to regulate and supervise non-bank financial services entities licensed or registered pursuant to the FSCA, No.8 of 2023 and the Securities Industry Act, 2021, including registered agents (TCSPs), securities and mutual funds</cite>. No primary source was located confirming whether the moratorium was extended, lifted, or replaced by a licensing route after its stated 31 December 2025 end date; this is a material open question given the current research date of 2026-10-03.

Standing sub-brief · as of 5 October 2026494 words · last cycle 2026-10-18

Crypto Licensing

Belize's virtual-asset licensing regime is governed by section 81 of the Financial Services Commission Act, Act No. 8 of 2023, in force since 15 April 2023. Section 81(1) prohibits a person from carrying on virtual-asset business in or from Belize without a licence issued by the Financial Services Commission. The prohibited activities are defined broadly: exchange of virtual assets, custody of virtual assets, transfer of virtual assets, provision of loans or deposits denominated in or secured by virtual assets, management or administration of virtual assets on behalf of another person, and participation in or provision of services related to the issuance, offer, or sale of virtual assets. This is a comprehensive, activity-based licensing prohibition rather than a narrow exchange-only regime, and it has been confirmed in force continuously since April 2023.

The same Act, however, barred the Financial Services Commission from issuing any section 81(1) licence until after 31 December 2025. This moratorium provision is itself confirmed in force from 15 April 2023, and it created a period of more than two and a half years during which the licensing prohibition applied in full but no licence could lawfully be granted to satisfy it — a structural feature of the regime rather than an oversight, and one that effectively foreclosed lawful virtual-asset business activity in or from Belize for that period absent an alternative legal basis.

The moratorium has now lapsed by its own statutory terms as of 31 December 2025. What now governs licence issuance is reported only from secondary, Tier 4 vendor sourcing: a Financial Services Commission (Digital Asset Services Licensing) Regulations, 2025 is described as having been issued on an interim basis in December 2025, with a further Financial Services Commission (Amendment) Act, 2026 described as intended to settle a permanent licensing framework. Neither instrument's text, nor a confirmed in-force date, has been located on a primary Financial Services Commission channel this cycle, so this finding is held at Probable rather than Confirmed confidence.

The specific fine and imprisonment maxima attached to a section 81(6)-(7) contravention were not located this cycle, meaning the precise penalty exposure for carrying on unlicensed virtual-asset business in Belize remains unconfirmed, even though the underlying prohibition and its statutory basis are well-established.

Outlook

The Financial Services Commission (Amendment) Act, 2026 is reported to be before Belize's National Assembly, with a permanent statutory virtual-asset licensing framework expected, as scheduled, around Q4 2026, though this estimate rests on Tier 4 sourcing and carries Uncertain confidence with a half-year uncertainty band. Primary-source confirmation of either the December 2025 interim Regulations' text and commencement date, or the Amendment Act's drafting status and legislative progress, is the key development to watch for in subsequent cycles. Until that confirmation is reached, the practical legal basis on which a virtual-asset business licence can presently be obtained in Belize remains unconfirmed on the public record, notwithstanding that the underlying section 81 prohibition and its 2023 moratorium provision are both well-established and confirmed.

Periodic update · new data 2026-10-18

Crypto Licensing

Belize crypto-licensing framework reached an operative threshold on 1 January 2026 when the statutory prohibition in section 81 of the Financial Services Commission Act, 2023 expired. That provision had barred the Commission from issuing licences for specified virtual-asset activities until 31 December 2025; unless someone was licensed under the Act, they could not conduct certain activities involving virtual assets on behalf of others, and the prohibition period meant no such licences could lawfully be granted during that window. With the prohibition lapsed, the Financial Services Commission (Digital Asset Services Licensing) Regulations, 2025, made under S.I. No. 162 of 2025 and in force since 30 December 2025, now function as the substantive licensing gateway.

Regulation 4(1) of those Regulations is the binding operative provision: a person shall not carry on digital-asset services unless that person holds a valid licence issued by the Commission. Regulation 4(2) makes contravention of that prohibition an offence, giving the licensing requirement criminal-law backing rather than merely administrative consequence. This is an in-force, binding obligation applying to any person carrying on digital-asset services in or from Belize, and it represents the primary compliance obligation facing digital-asset businesses in the jurisdiction today.

The Regulations are, however, explicitly structured as an interim measure. Regulation 12 provides that the Regulations expire upon entry into force of the Financial Services Commission (Amendment) Act, 2026, meaning the entire licensing framework currently in operation is scheduled to be superseded once that Act commences. Regulation 13 addresses the transition for firms already licensed under the interim regime, preserving existing licences until their own stated expiry dates rather than causing an abrupt lapse in authorisation at the moment the Regulations themselves expire. This transitional design, under which currently licensed firms retain authorisation even as the framework that licensed them is phased out, is a structurally significant feature of the regime: it indicates the FSC approach is intended to avoid a regulatory gap for existing licence-holders during the changeover.

What remains unresolved is the content and commencement timetable of the Financial Services Commission (Amendment) Act, 2026 itself. Its existence and title were confirmed, but its substantive provisions could not be retrieved or assessed this cycle, which means the shape of the licensing regime that will eventually replace the current interim Regulations is not yet known. This is recorded as a gap in the evidence base, not as a finding about the Amendment Act content, and it should not be read as suggesting any particular outcome for what the successor regime will require.

Outlook

The key forward-looking question for Belize crypto-licensing regime is the timing and content of the Financial Services Commission (Amendment) Act, 2026 entry into force, at which point the current interim Regulations will expire by their own terms under regulation 12. Firms currently licensed under the 2025 Regulations should expect their existing licences to be preserved through the transition per regulation 13, but the terms on which new licences will be issued, or existing ones renewed, once the Amendment Act commences cannot be assessed until its text is retrieved. Exact penalty figures for contravention of the regulation 4 licensing requirement, referenced generally in section 81 of the 2023 Act, were likewise not retrieved this cycle and remain an open item.

Sources and findings (4)

T2 · Caribbean Financial Action Task Force (CFATF)Caribbean Financial Action Task Force (CFATF) — FSCA (No. 8 of 2023) s.81(3): <cite index="74-11">the operation of VASPs is prohibited until December 31, 2025, by virtue of s.81 (3) of the FSCA</cite>; the duty binds any natural or legal person seeking to carry on VASP business in or from Belize, with no exception or carve-out identified in the sources reviewed.retrieved 2026-10-03M5bindingin forceour coverage gap, expected to resolve on a re-run
T2 · Caribbean Financial Action Task Force (CFATF)Caribbean Financial Action Task Force (CFATF) — The s.81(3) VASP prohibition was drafted as a time-bound moratorium ending 31 December 2025; as of the 2026-10-03 research date, no FSC notice, gazette amendment, or follow-up CFATF/FATF report was located confirming whether the prohibition lapsed, was extended, or was superseded by a licensing regime for the post-expiry period.retrieved 2026-10-03M5non-bindingour coverage gap, expected to resolve on a re-run
T2 · Caribbean Financial Action Task Force (CFATF)Caribbean Financial Action Task Force (CFATF) — <cite index="94-5">Belize has established measures for non-compliance with the prohibition</cite> on VASP operation, and the FSC's predecessor/related supervisory practice includes sanctioning unlicensed conduct, though the precise fine/penalty schedule attaching specifically to s.81(3) breaches (fixed amount, criminal sanction, or administrative measure) was not located in primary legislative text during this pass.retrieved 2026-10-03M4bindingin forceour coverage gap, expected to resolve on a re-run
T2 · Caribbean Financial Action Task Force (CFATF)Caribbean Financial Action Task Force (CFATF) — No prudential own-funds or capital-adequacy regime for VASPs exists in Belize because VASP operation itself is statutorily prohibited; <cite index="74-10">the assessment team agreed with the conclusion that VASPs could be considered a least important sector</cite>, and no licensing gateway exists under which a capital requirement could attach.retrieved 2026-10-03M2non-bindinga fact about the regime

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Belize has not enacted a statutory token taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs. The FSCA addresses virtual assets only through the blanket VASP operating prohibition rather than through asset-class classification, so no classification claims can be grounded in primary law.

Standing sub-brief · as of 18 October 2026424 words · last cycle 2026-10-18

Token Classification

Belize token-classification landscape saw one concrete development this cycle: a Financial Services Commission Policy Statement, dated 21 May 2026, titled Regulatory Classification of Contracts for Differences Referencing Digital Assets, which classifies Crypto CFDs as securities. This brings such instruments within the scope of the Securities Industry Act, 2021 rather than the Digital Asset Services Licensing Regulations, 2025, meaning a provider offering Crypto CFDs falls under securities-law licensing and conduct requirements administered by the Commission rather than under the digital-asset-services licensing gateway addressed above.

This classification is binding and in force as of the Policy Statement date, and it resolves, for this one specific instrument type, a question that is otherwise unresolved for digital assets generally in Belize: no general statutory test distinguishing categories such as payment tokens, utility tokens, asset-referenced tokens, or e-money-like tokens was located in the evidence reviewed this cycle. The Crypto CFD classification should therefore be read as a narrow, product-specific precedent rather than as evidence that Belize has settled a general token taxonomy. A product that is structured as a derivative contract referencing a digital asset, as a Crypto CFD is, is treated differently under this Policy Statement than a product that involves direct dealing in or custody of the underlying digital asset itself, which would more likely fall under the Digital Asset Services Licensing Regulations regime addressed in the companion Crypto Licensing module.

The practical consequence for market participants is a bifurcated compliance pathway depending on product structure: a Crypto CFD provider looks to the Securities Industry Act, 2021 and whatever licensing and conduct obligations the Commission applies under that Act, while a provider dealing directly in digital assets or operating custody or exchange services looks to the Digital Asset Services Licensing Regulations, 2025. The evidence reviewed this cycle does not indicate any overlap-resolution mechanism for a product or business model that could plausibly be classified under either framework, and that gap is worth flagging for any entity whose offering sits at the boundary between a derivative referencing a digital asset and direct dealing in one.

Outlook

Whether Belize moves toward a more general statutory token-classification framework, whether through the pending Financial Services Commission (Amendment) Act, 2026 or through further Commission policy statements extending the approach taken for Crypto CFDs to other instrument types, is the open question for this module going forward. Until such a general framework emerges, classification determinations in Belize should be expected on a product-by-product basis, following the precedent set by the May 2026 Policy Statement for the specific case of Crypto CFDs.