Ecuador#
No crypto-asset licensing statute in force; Proyecto de Ley Orgánica de Activos Virtuales qualified by CAL on 2026-10-19 and referred to Comisión de Seguridad Integral, with an unresolved institutional conflict with the Junta Monetaria over crypto-payment authorisation.
The scale of the market's adjustment to this deadline is significant. A 29 June 2026 snapshot recorded only around 230 to 244 MiCA-authorised CASPs against a base of more than 3,000 firms that had been registered as VASPs under prior national regimes across the EU. That gap looked stark at the moment the deadline fell, but the count moved quickly afterward — to 283 authorised firms by 10 July 2026 and 323 by 21 July 2026 — indicating a wave of post-deadline authorisations working through national competent authorities rather than a permanent contraction of the licensed population. Any reading of the 230-244 figure should treat it as a point-in-time snapshot rather than a settled total.
A further calibration is needed on the deadline itself. While 1 July 2026 functions as the EU-wide backstop for the end of national transitional arrangements, it is not a uniform national compliance date. Several Member States exercised the discretion MiCA affords them to shorten their own transitional periods: Germany and Ireland set a twelve-month period, the Netherlands, Poland, Latvia, Hungary and Slovenia set six months, and Sweden set nine months. Effective compliance deadlines in those jurisdictions therefore fell earlier than the EU-wide 1 July 2026 date, and the composed record here reflects a downgraded confidence rating on any claim that treats 1 July 2026 as a uniform national cliff-edge, pending dedicated Member-State-level verification.
Outlook
The near-term question is enforcement follow-through: how national competent authorities and ESMA handle the substantial population of firms that had not secured MiCA authorisation by the EU-wide deadline, and whether the rapid post-deadline authorisation growth observed in July 2026 continues to close the gap between previously-registered VASPs and MiCA-licensed CASPs. A secondary and more granular question, flagged as an under-indexed area at the EU supra-national level, is how enforcement plays out differentially across the Member States that adopted shorter national transitional periods, where firms have already been operating outside grandfathering protection for longer than the EU-wide backstop would suggest.
Crypto Licensing
Ecuador has no existing licensing or registration gateway for virtual-asset activity. That gap is now the subject of the country's first-ever Virtual Assets Organic Law bill, qualified for legislative processing by the National Assembly's Legislative Administration Council on 19 October 2026 and authored by legislator Inés Alarcón. The bill has been referred to the Comisión de Seguridad Integral and sits at committee stage, meaning it has cleared a procedural threshold for consideration but has not been enacted, debated on the floor, or reduced to a text with settled provisions on every point.
As proposed, the bill would create a mandatory registration regime applicable to natural and legal persons engaged in the issuance, exchange, transfer, custody, administration or intermediation of virtual assets. It contemplates special authorisations for activity assessed as carrying higher risk or higher exposure, suggesting a tiered approach to supervision rather than a single uniform licence class, though the precise tiering criteria are not established from the sources reviewed. The bill's institutional design splits functions across several existing bodies: the Financial Policy Board, the Superintendencies, the Banco Central del Ecuador, UAFE and the Prosecutor's Office, rather than concentrating supervision in a single new authority as some other jurisdictions have done. No provision number is available from sources reviewed for the registration requirement itself.
This legislative development sits on top of, rather than replacing, the existing 2024 AML reform position: virtual-asset service providers already report transaction and beneficial-ownership information to UAFE as obligated entities, a duty that predates and is independent of the pending bill. What the bill would add, if enacted, is a registration and authorisation gateway that does not exist today; currently, an exchange or custodian serving Ecuadorian users does so without any licensing requirement specific to virtual-asset activity, relying instead on the general AML reporting duty alone.
Two structural questions remain unresolved in the material available. First, which body, among the Junta de Política y Regulación Monetaria y Financiera, a new Superintendencia, or UAFE, would function as the primary supervisor of registered CASPs under the bill as drafted has not been established. Second, whether the bill itself specifies custody-segregation rules, prudential-capital requirements or market-abuse provisions, or instead defers these matters to future secondary regulation, is similarly unsettled from the committee-stage reporting reviewed. Both questions bear directly on how substantive the eventual registration regime would be in practice, and neither can be answered from the bill's qualification for processing alone.
Outlook
The bill's next material marker is its progress through the Comisión de Seguridad Integral; no legislative timeline for enactment is available from sources reviewed, and the cited horizon of 2027 reflects the general expectation that committee-stage bills of this kind in Ecuador's Assembly take a period of further deliberation rather than any date stated in the bill's own text. Resolution of the primary-supervisor question and clarification of whether custody, capital and market-conduct rules sit in the bill or in deferred secondary regulation are the two developments most likely to determine how substantive the eventual licensing gateway will be. Until either the bill advances further or secondary sourcing clarifies these points, Ecuador's virtual-asset sector continues to operate without a licensing requirement specific to the activity, governed only by the general AML reporting duty already in force under the 2024 reform.
Sources and findings (7)
- T1ESMA — After 1 July 2026, any entity providing crypto-asset services to EU clients without a MiCA licence is in breach of EU law and must cease offering such services. retrieved M5 binding in force
- T1ESMA — Article 143(3) MiCA allowed entities providing crypto-asset services under national law before 30 December 2024 to continue operating under a grandfathering clause until 1 July 2026 or until granted/refused MiCA authorisation. retrieved M4 binding in force
- T3CoinDesk — As of the 1 July 2026 transitional deadline, only around 230-244 crypto-asset service providers were MiCA-authorised, versus more than 3,000 previously-registered VASPs across the EU under prior national regimes. retrieved M3 non-binding
- T1ESMA — ESMA has called on unauthorised CASPs to wind down their EU activities in an orderly manner while safeguarding client interests following the end of the MiCA transitional period. retrieved M5 binding in force
- T1Proyecto de Ley Orgánica de Activos Virtuales — Proposes a mandatory registration regime for natural/legal persons engaging in issuance, exchange, transfer, custody, administration or intermediation of virtual assets, with special authorisations for higher-risk/higher-exposure activity retrieved M4 non-binding proposed
- T1Ecuador — No statute currently authorises or licenses virtual-asset service provision in Ecuador; the pending bill, qualified by CAL on 2026-10-19, is not yet enacted. retrieved M4 non-binding
- T4Ecuador — No enforcement-penalty regime for unauthorised virtual-asset activity was located this cycle, consistent with the absence of an in-force licensing statute. retrieved M2 non-binding