Bermuda Crypto Fund License: 2026 Guide & Costs

By Mardo Soo, Founder & CEO, Consulting24 (X24Consulting OÜ) · Updated 2026-06-19

Bermuda has established itself as a leading jurisdiction for digital asset funds, offering a clear regulatory framework under the Bermuda Monetary Authority (BMA). The crypto fund license Bermuda is designed for fund managers who wish to operate a collective investment scheme focused on digital assets. This page provides an authoritative overview of the license, its requirements, costs, and how Consulting24 can assist with the process.

Bermuda's proactive approach to regulating digital assets, including the Digital Asset Business Act 2018 and the Investment Funds Act 2006, makes it an attractive destination for fund managers seeking credibility and access to global investors. The BMA's rigorous standards ensure that licensed funds meet high compliance and transparency requirements.

Consulting24 advises and coordinates the Bermuda crypto fund license application, leveraging our experience with over 500 crypto licenses in other jurisdictions. While we do not directly file in Bermuda, we guide you through the process and can help structure your fund with a Panama company setup at a flat EUR 6,000.

What is the Bermuda Crypto Fund License?

The Bermuda crypto fund license is a regulatory authorization issued by the Bermuda Monetary Authority (BMA) under the Investment Funds Act 2006, as amended by the Digital Asset Business Act 2018. It allows fund managers to operate collective investment schemes that invest primarily in digital assets, including cryptocurrencies, tokens, and other blockchain-based assets.

Bermuda distinguishes between different fund structures: professional funds (for qualified investors), institutional funds, and public funds. The most common for crypto is the professional fund, which requires a minimum investment of USD 100,000 per investor and is limited to 20 investors. The BMA also requires the fund to have a licensed fund administrator, custodian, and auditor based in Bermuda.

As of 2026, Bermuda remains a non-EU jurisdiction, so it is not subject to MiCA. This gives fund managers flexibility in capital requirements and operational structure compared to EU member states. However, the BMA expects high standards of governance and transparency. For example, the fund must appoint a resident director and maintain a physical office in Bermuda. The license is ideal for funds targeting institutional investors who value regulatory oversight.

Who Needs a Bermuda Crypto Fund License?

Any entity that manages a pooled investment vehicle focused on digital assets and wishes to market to investors globally, particularly institutional and high-net-worth individuals, should consider the Bermuda crypto fund license. It is ideal for:

• Fund managers launching a new digital asset fund
• Existing funds seeking a reputable offshore jurisdiction
• Family offices diversifying into crypto
• Venture capital firms investing in blockchain startups

Bermuda is particularly suited for funds targeting US and international investors due to its strong regulatory reputation and tax neutrality. For example, a hedge fund manager based in New York who wants to offer a crypto fund to qualified purchasers may choose Bermuda to benefit from its zero-tax regime and established fund infrastructure. Similarly, a European venture capital firm looking to raise a blockchain fund might prefer Bermuda over EU jurisdictions to avoid MiCA's capital requirements.

If you are unsure whether Bermuda is right for you, Consulting24 can help evaluate your needs. We also offer direct setup in Lithuania and Estonia for those who prefer EU-regulated alternatives.

License Type and Regulator

The Bermuda crypto fund license is regulated by the Bermuda Monetary Authority (BMA), the island's integrated financial regulator. The BMA oversees both the fund itself and the fund's service providers (administrator, custodian, auditor). The license type is typically a 'Professional Class' fund under the Investment Funds Act, which requires:

• Minimum initial investment per investor: USD 100,000
• Maximum number of investors: 20
• Fund must be closed-ended or open-ended as per the offering memorandum

The BMA also requires the fund to have a physical presence in Bermuda, including a registered office and at least one director who is a resident of Bermuda. The fund's constitutional documents must be approved by the BMA, and the offering memorandum must disclose all material risks.

For funds that wish to accept more than 20 investors or smaller minimum investments, the BMA offers institutional and public fund classes, but these come with higher capital requirements and ongoing disclosure obligations. Most crypto fund managers opt for the professional class due to its flexibility.

Cost and Timeline

Total setup costs typically range from USD 25,000 to 50,000, with annual ongoing costs of USD 40,000 to 100,000. The application process takes 3-6 months from submission to approval, depending on the complexity of the fund structure and the completeness of the application.

For example, a straightforward professional fund with pre-selected service providers may be approved in 3 months, while a fund with complex investment strategies or multiple classes may take up to 6 months. The BMA charges a non-refundable application fee of USD 2,500, and the annual fee is USD 2,500. Legal fees for drafting the offering memorandum and constitutional documents typically range from USD 15,000 to USD 30,000.

Ongoing costs include the fund administrator (USD 20,000-50,000 per year), custodian (USD 10,000-30,000), and auditor (USD 5,000-15,000). These fees vary based on the fund's size and complexity. Consulting24 offers a Panama company setup at a flat EUR 6,000, which can serve as the fund's operational entity or holding company.

Capital Requirement

Bermuda does not prescribe a specific minimum capital requirement for professional funds under the Investment Funds Act. However, the BMA expects the fund to have sufficient capital to cover operational expenses and to demonstrate financial soundness. Typically, funds are capitalized with at least USD 100,000 in initial seed capital from the manager or investors. The fund's offering memorandum must disclose the capital structure.

In contrast, the EU's Markets in Crypto-Assets Regulation (MiCA) imposes capital tiers of EUR 50,000 / 125,000 / 150,000 for CASPs, but Bermuda's regime is more flexible, making it attractive for smaller fund managers. For example, a fund manager with only USD 200,000 in seed capital can launch a professional fund in Bermuda, whereas in Lithuania they would need at least EUR 125,000 for a CASP license. However, the fund must still demonstrate that it has enough capital to operate for at least 12 months.

Consulting24 advises on capital structuring to meet BMA expectations. This is general guidance, not legal advice. Always consult a Bermuda-licensed lawyer for specific capital requirements.

Tax Treatment

Bermuda has no corporate income tax, capital gains tax, or withholding tax. Funds are exempt from Bermuda taxation, provided they are not resident in Bermuda for tax purposes (i.e., managed and controlled offshore). The fund must register for Bermuda's Economic Substance regime, but for pure investment funds, the requirement is minimal. Investors are taxed in their home jurisdictions; Bermuda does not impose any additional taxes on the fund or its distributions.

For example, a Bermuda fund that generates USD 1 million in capital gains pays zero tax in Bermuda. The fund's investors, if US-based, would be subject to US tax on their share of the gains, but they can benefit from the fund's tax transparency. Bermuda also has no VAT or stamp duty on fund transactions.

This tax neutrality is a major advantage over EU jurisdictions like Lithuania, where corporate income tax is 15% on profits. However, funds must ensure they do not create a permanent establishment in a high-tax jurisdiction. Consulting24 can help structure the fund to maintain tax efficiency.

Allowed Activities

A Bermuda crypto fund license permits the fund to engage in the following activities:

• Investing in digital assets (cryptocurrencies, tokens, NFTs)
• Staking and lending of digital assets (if disclosed in the offering memorandum)
• Participation in DeFi protocols (subject to BMA approval)
• Holding fiat currency for operational purposes
• Issuing fund shares to qualified investors

The fund must not engage in proprietary trading, use beyond disclosed limits, or provide custody services to third parties (custody is outsourced to a licensed custodian). The BMA also requires that the fund's investment strategy be clearly defined in the offering memorandum. For example, a fund that plans to actively trade derivatives on crypto exchanges must disclose this and may need additional approvals.

Bermuda's regime is less restrictive than MiCA in terms of allowed activities. For instance, a Bermuda fund can invest in DeFi protocols without needing a separate license, whereas an EU CASP may need additional authorization for such activities. However, the BMA expects strong risk management and disclosure.

Step-by-Step Application Process

1. Pre-application consultation: Discuss fund structure, service providers, and timeline with Consulting24. We help you identify the right class of fund and prepare a project plan.
2. Engage local service providers: Appoint a Bermuda-licensed fund administrator, custodian, auditor, and legal counsel. Consulting24 can introduce you to reputable firms.
3. Prepare legal documents: Draft the offering memorandum, fund constitution, and service agreements. This is typically done by Bermuda legal counsel and takes 4-8 weeks.
4. Submit application to BMA: File Form 1 (Application for Registration) along with supporting documents and the USD 2,500 fee. The BMA will acknowledge receipt within 5 business days.
5. BMA review and queries: The BMA typically takes 4-8 weeks to review and may request additional information. Common queries include clarification on the investment strategy, service provider credentials, and AML policies.
6. Approval and licensing: Once satisfied, the BMA issues a certificate of registration. The fund can then commence operations. The total process from submission to approval averages 3-6 months.
7. Ongoing compliance: File annual returns, audited financial statements, and maintain economic substance. The BMA also conducts periodic inspections.

Consulting24 coordinates the entire process, ensuring that all documents are complete and deadlines are met. We also offer a Panama company setup at EUR 6,000 as a complementary service for the fund's operational entity.

Banking and Payments

Opening a bank account for a Bermuda crypto fund can be challenging due to the perceived risk. However, Bermuda has several licensed banks that accept digital asset funds, such as HSBC Bermuda, Butterfield Bank, and Clarien Bank. The fund will need to provide its license, offering memorandum, and KYC documents. The application process typically takes 2-4 weeks.

Alternatively, the fund can use a payment services provider or a crypto-friendly bank in another jurisdiction, such as Lithuania or Estonia, where Consulting24 can assist with Lithuania crypto license or Estonia crypto license for the fund's operational entity. For example, a Bermuda fund might open a bank account in Lithuania for fiat transactions, while using a Bermuda custodian for digital assets.

Consulting24 advises on banking options based on the fund's investor base and transaction volumes. We recommend starting the bank account application early, as delays can postpone the fund's launch.

Benefits of the Bermuda Crypto Fund License

• Regulatory credibility: BMA is a respected regulator, enhancing investor confidence. Many institutional investors require their fund managers to be regulated by a Tier-1 jurisdiction like Bermuda.
• Tax neutrality: No corporate tax, capital gains tax, or withholding tax. This allows the fund to compound returns without tax leakage.
• Flexible capital requirements: No statutory minimum capital for professional funds, making it accessible for smaller managers.
• Access to global investors: Bermuda is a recognized international financial centre with a deep pool of institutional investors.
• Established legal framework: Common law jurisdiction with clear fund regulations and a supportive court system.
• No MiCA compliance: As a non-EU jurisdiction, Bermuda funds are not subject to MiCA's capital tiers and operational restrictions.

These benefits make Bermuda a top choice for crypto fund managers who prioritize regulatory quality and tax efficiency. However, the setup and ongoing costs are higher than in some other jurisdictions. Consulting24 can help you weigh these factors against alternatives like Panama, where a company setup costs EUR 6,000 flat.

Compliance and Trust

Bermuda's regulatory regime is known for its high standards. The BMA conducts ongoing supervision, including annual reviews and on-site inspections. Funds must comply with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, as well as economic substance requirements. The fund must appoint a compliance officer and a money laundering reporting officer (MLRO) who are based in Bermuda.

Consulting24 advises on structuring your fund to meet these obligations. This is general guidance, not legal advice. Always consult a Bermuda-licensed lawyer for specific compliance matters. For example, the fund must maintain a risk-based AML program, including customer due diligence on all investors and ongoing transaction monitoring. The BMA expects the fund to file suspicious activity reports (SARs) when necessary.

Trust is built through transparency. The fund's audited financial statements must be filed with the BMA annually and made available to investors. The BMA also publishes a list of licensed funds on its website, which enhances credibility.

Common Mistakes to Avoid

• Underestimating costs: Annual service provider fees can be high; budget accordingly. Many first-time fund managers are surprised by the USD 40,000-100,000 in annual costs.
• Ignoring economic substance: The fund must have a physical presence in Bermuda, including a registered office and local directors. Attempting to operate without substance can lead to license revocation.
• Incomplete documentation: The BMA requires a detailed offering memorandum; incomplete submissions cause delays. Ensure all risk factors and investment strategies are fully disclosed.
• Choosing the wrong fund structure: Professional funds are suitable for most, but public funds require more capital and disclosure. Selecting the wrong class can result in additional costs and regulatory scrutiny.
• Delaying bank account opening: Bank account applications can take weeks; start early to avoid delaying the fund launch.
• Failing to engage experienced local counsel: Bermuda's legal requirements are specific; working with inexperienced advisors can lead to errors.

Consulting24 helps you avoid these pitfalls by coordinating with trusted local partners and providing a structured project plan.

Alternatives and Comparisons

Compared to other jurisdictions, Bermuda offers a unique mix of tax neutrality and regulatory rigour. Here is how it stacks up:

For fund managers seeking a low-cost, fast setup, Panama offers a flat EUR 6,000 fee and no capital requirement, but it lacks the regulatory credibility of Bermuda. Lithuania, under MiCA, requires EUR 125,000 capital and 15% corporate tax, but offers access to the EU single market. Consulting24 advises on the best fit for your fund, including jurisdictions we serve directly.

Other alternatives include the Cayman Islands (similar to Bermuda but with higher costs) and Switzerland (high credibility but expensive). Consulting24 can provide detailed comparisons upon request.

Why Choose Consulting24?

Consulting24 has obtained over 500 crypto licenses globally, including in Estonia, Lithuania, and Panama. For Bermuda, we provide advisory and coordination services, connecting you with local legal and compliance experts. Our Panama company setup at EUR 6,000 is an ideal base for the fund's operational entity. We help you navigate the entire process, from structuring to application support.

We offer a free initial consultation to discuss your fund's objectives and recommend the best jurisdiction. Contact us on WhatsApp to book a consultation. Our team is available to answer your questions and provide a tailored proposal.

Official sources

• Bermuda Monetary Authority
• Bermuda Ministry of Finance

Related jurisdictions

Mardo Soo · CEO, Consulting24Personally advises on jurisdiction selection. 500+ crypto licenses across Estonia, Lithuania & Panama. LinkedIn →

General guidance, not legal advice. Rules and fees evolve — we confirm current requirements for your case.