Forex Broker Licence: Jurisdictions Compared (FCA, CySEC, ASIC, DFSA, ADGM and Offshore)

A forex broker licence is the authorisation a financial regulator grants a firm to deal in FX and CFDs with clients, and the jurisdiction decides which clients the firm may serve, how much leverage its retail clients get and how much capital it must hold. TradeCore compares eight regulators below, every figure linked to a primary source.

TradeCore is forex brokerage software for new FX/CFD brokers, and the licence is one of the first decisions a new brokerage makes. A brokerage's licence can be already held or still in progress: a new brokerage can set up its signup flows, client portal and connections on TradeCore's free plan alongside the licensing work.

This guide compares the FCA, CySEC, ASIC, the DFSA, the FSRA in ADGM, the FSCA, the FSA Seychelles and the VFSC on what each publishes: where the licence reaches, the retail leverage cap, negative balance protection and minimum capital. It does not rank them, because the right jurisdiction depends on your clients, your execution model and your capital. Rules change, so read every figure as a starting point for your own legal advice.

What is a forex broker licence?

A forex broker licence lets a firm offer FX and CFD trading to clients from a jurisdiction, under that regulator's conduct and capital rules. Its reach works in three ways: the home jurisdiction that grants it, any passport that extends it to other states, and the permission a host country's own regulator gives for business in that country.

The FSA Seychelles spells out the third case: a securities dealer licence covers only securities business done in the Seychelles, and a dealer needs an exemption, a cross-border agreement or approval from the regulator in any other jurisdiction where it wants to offer services.

How do the main forex licence jurisdictions compare?

The table below compares eight forex licence jurisdictions on the points each regulator publishes. Each figure links to its primary source: the regulator's rulebook, policy statement, guidance or FAQ, or for South Africa's ODP route, National Treasury's memorandum on the Financial Markets Act regulations. A dash means the requirement was not established from the sources checked.

The sources checked did not establish the FSCA's retail leverage, negative balance protection or minimum capital, or negative balance protection under the FSA Seychelles and the VFSC; ask each regulator directly. The Seychelles figure is a minimum issued and paid-up share capital, and the Vanuatu figure is a deposit; the VFSC's guidance also expects capital sized to the business plan for the first three years.

The leverage caps are retail limits on opening a position; professional clients sit outside them. The DFSA states its rule as a 3.3% minimum margin, which works out at about 30:1. ASIC's order is due to expire on 23 May 2027, and ASIC opened a consultation in 2026 on extending it for a further 10 years, so check the current position before you plan around it.

Minimum capital is a floor, not a budget. The figures in the table are the published minimums; a firm's own-funds requirement can be higher once the regulator's other prudential tests apply.

Which forex licences reach clients in other countries?

Of the eight, CySEC is the one whose licence carries a passport. Under MiFID II, a Cyprus investment firm notifies CySEC for each EEA state where it wants to provide services across borders, on Form 87-00-04, or to open a branch on Form 87-00-06.

The other seven licences are home-jurisdiction licences. The FCA licenses firms in the United Kingdom and ASIC in Australia; the DFSA and the FSRA license firms in two financial free zones, the DIFC in Dubai and ADGM in Abu Dhabi. For business in another country, the question becomes that country's rules: the FSA Seychelles, for example, tells dealers to hold the host regulator's exemption, agreement or approval, and tells clients to check that a platform is licensed where they live.

Many brokerages answer the reach question with more than one entity, each licensed for the markets it serves. Each entity then runs under its own regime, with its own onboarding, leverage and reporting rules.

What does an ADGM forex licence require?

In Abu Dhabi Global Market, the Financial Services Regulatory Authority (FSRA) regulates FX and CFDs as OTC leveraged products under chapter 23 of its Conduct of Business Rulebook. A retail client posts at least 3.33% margin on major currency pairs and 5% on non-major pairs, gold and major equity indices. Positions close when net equity falls below 50% of the margin requirement, and a retail client's liability is limited to the funds in the trading account.

The same chapter bars promotions, bonuses and other inducements to retail clients for these products. On capital, PRU 3.3.2 sets US$2 million base capital for a firm dealing as matched principal in OTC leveraged products with retail clients.

The FSRA's supplementary guidance of December 2023 says it is not minded to approve start-up operations seeking to offer OTC leveraged products to retail clients, because they lack a track record. It also sets experience expectations for key people:

• Senior Executive Officer — at least ten years dealing with retail clients in similar products, in an equivalently regulated environment
• Licensed Director — at least seven years of the same experience
• Senior managers, Compliance Officer and MLRO — at least five years each

The DFSA in the DIFC runs a comparable regime: a 3.3% minimum margin on major currency pairs for retail clients, liability limited to the trading account, and US$2 million base capital for a firm dealing as principal, or US$500,000 if it deals only as matched principal.

How much does a forex licence cost by jurisdiction?

A forex licence costs what the regulator charges plus what it makes you hold and hire. Four lines make up the bill:

• Application and annual fees — set by the regulator and published by some
• Regulatory capital — the minimum in the table above, plus the own-funds and liquidity tests on top
• People — the officers the regulator expects, such as a compliance officer and an MLRO
• Legal, audit and policies — quoted by law firms and auditors, and different in every jurisdiction

The regulators' published application and annual fees, kept separate from capital:

Some regulators also hold money on top of the fee. Vanuatu's Financial Dealers Licensing Act requires a VT 5,000,000 deposit with the Commission before a principal's licence is granted. The DFSA adds a further 100% of its application fee where one of the factors in FER 2.1.1 applies, such as a multi-level corporate structure. A dash in the fee table means the fee was not established from the sources checked.

Where both are published, the capital floor is far larger than the fee: compare the FSRA's US$40,000 application fee with its US$2 million base capital for retail OTC leveraged products. For the full start-up budget beyond the licence, read how much it costs to start a forex brokerage.

What protections come with an onshore forex licence?

Onshore regulators pair the leverage cap with a set of retail protections. The FCA's permanent CFD rules require positions to close when account funds fall to 50% of the margin needed, cap a client's losses at the funds in the CFD account, ban trading incentives, and require a standard risk warning showing the share of retail accounts that lose money.

Investor compensation differs by jurisdiction. In the UK, the FSCS covers investments up to £85,000 per eligible person, per firm. In Cyprus, the Investor Compensation Fund pays covered clients 90% of their claim or €20,000, whichever is lower.

How does TradeCore run brokerages with more than one licence?

TradeCore Compliance gives every licence its own regulatory regime, with per-jurisdiction rules for licences such as CySEC, FCA and ASIC configured from one dashboard. Signup flows are scoped per jurisdiction, and adding a jurisdiction is a configuration change, done the same day. TradeCore ships configurable seeded defaults for 19 regulatory regimes with 26 rules each, including every regulator in the table above, and every rule can be overridden per brand.

A few of TradeCore's seeded defaults, as worked examples:

• FCA — 30:1 maximum leverage and a 56-day complaint response deadline
• CySEC — 30:1 maximum leverage
• ASIC — 30:1 maximum leverage and the AUD 10,000 AUSTRAC threshold transaction report
• MAS — 20:1 maximum leverage and an SGD 20,000 threshold
• VFSC — leverage not capped by the regime

These values are TradeCore's configurable seeded defaults, not legal advice: your compliance team checks every value and sets each rule for its own licence. TradeCore does not file regulatory reports: your compliance team files, and each regime records where suspicious-activity reports go and the threshold amount.

TradeCore's free plan carries one regulatory licence, and a regulated brand may run on it. Core carries any number of licences, at €2,500 a month, flat, with no per-trader, per-trade or setup fees. See TradeCore pricing for what each plan includes.

Can a brokerage set up before its licence is granted?

Yes. A brokerage still getting licensed can set up on TradeCore's free plan alongside the licensing work: its signup flows, client portal and connections, before its first client. The environment is ready as soon as you finish signup, and there is no card to sign up — a card the first time you buy an add-on.

For the full sequence from business plan to first client, follow how to start a forex brokerage, step by step.

Related guides

• How to start a forex brokerage: a step-by-step guide
• How much does it cost to start a forex brokerage?
• Forex CRM: what a broker CRM does
• A forex broker marketing plan