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Crypto License

New Zealand FSP Registration for Crypto Payment Providers

nz
Mark Paat

Mark Paat

Last updated: 11 min read

Fact Checked by: Maksim Gasanbekov

Overview

Service Snapshot

Setting up a New Zealand business that uses cryptocurrency for payments, conversion or transfers starts with classifying the services it provides. Gofaizen & Sherle helps crypto payment providers assess whether they need to register as a financial service provider (FSP) in New Zealand, prepare the application, and identify any separate authorization their activities require.

  • Payment and value transfer with cryptocurrency functionality Business model
  • As FSP on the Financial Service Providers Register (FSPR), administered by the Companies Office Registration
  • Department of Internal Affairs (DIA), which oversees anti-money laundering and countering financing of terrorism AML/CFT supervision
  • Financial Markets Authority (FMA) licensing where the activity requires it Separate licensing
  • A qualifying director and physical registered addresses for a New Zealand company Company setup
  • On request Professional fee

The Right Fit for Your Business

sign positive

Positive Signs

  • Your business can show who receives, converts, holds and transfers customer funds.
  • You can show where your clients and operations are based and explain your New Zealand connection.
  • Your team can implement customer checks and transaction monitoring before launch.
sign warning

Warning Signs

  • Your intended customers are exclusively offshore, or you would operate from overseas serving only New Zealand wholesale clients.
  • You expect incorporation or a registered address by itself to establish a sufficient local connection.
  • You plan to hold repayable balances or offer tokens with investment rights.

Use these signs to guide your assessment.

Regulatory Scope for Crypto Payments and Transfers

Classify services by what they do with customer assets.

  • Payments and transfers
  • Cryptocurrency exchange
  • Wallets and custody
  • Brokerage and token-based products

New Zealand has no general cryptocurrency license or dedicated payment service provider or e-money license. The FSPR lists registered FSPs and their services. Registration carries no endorsement.

Subject to exceptions, you must register if you serve New Zealand clients above the applicable threshold, provide financial services as an AML/CFT reporting entity, or provide services that trigger a separate statutory licensing or registration requirement.

Taking deposits or accepting other repayable funds outside a genuine trust arrangement may trigger debt-security or deposit-taking rules. Tokens representing debt, equity, interests in managed investment products or derivatives can also bring additional rules into scope. Regulated retail offers may require licensing and disclosure. Wholesale or offshore exceptions leave the rules against misleading or deceptive conduct in place.

For crypto projects, explore our ready-made crypto companies and crypto licensing services.

What Gofaizen & Sherle Will Handle

We trace who receives, holds and transfers the funds.

  1. Service Classification

    • Classify services using client markets, custody, transfers and token rights.
  2. Company Structure

    • Review ownership, director eligibility and registered addresses.
    • Identify the company documents and director consents to prepare.
  3. AML/CFT Policies

    • Help prepare the written risk assessment, program and policies for customer checks and transfers where required.
  4. Application Support

    • Help prepare filings and responses to authority requests, and check dispute scheme requirements.

Cost and Services

Payment and Transfer Setup Support

Price on request

  • service and company structure assessment
  • preparation of applicable AML/CFT policies and application materials
  • support with authority follow-up on the agreed application

The quote lists professional fees, official fees, levies and third-party charges separately.

How the Setup Works

  1. Classify the Services

    You describe the services. Gofaizen & Sherle identifies the applicable requirements.

  2. Set Up the Company and Controls

    You approve the structure and arrange signed consents. For a New Zealand company, appoint at least one director who lives in New Zealand or lives in Australia and currently directs an Australian-incorporated company. Gofaizen & Sherle helps prepare company documents and applicable AML/CFT policies.

  3. Prepare the Filing

    Gofaizen & Sherle helps prepare the application. The Companies Office reviews the FSPR application before payment. If you apply only for licensed services, obtain authorization for at least one before the Companies Office completes FSPR registration.

  4. Answer Follow-up

    You supply any information the authority requests. Gofaizen & Sherle helps you respond. Launch once you meet the applicable conditions.

What We Need From You

  • laptop

    Services and Token Rights

    Share your business plan or service description and the agreements that explain what customers receive.

  • laptop

    Clients and Markets

    Identify customer locations, retail or wholesale status and where you intend to operate.

  • laptop

    Company and Ownership

    Provide an ownership chart, director details and proposed registered addresses.

  • laptop

    Funds, Technology and Controls

    Share fiat and crypto flow diagrams, custody arrangements, platform contracts and existing AML/CFT policies.

Our expertise

Why Gofaizen & Sherle?

We combine legal, regulatory and technical expertise to support asset tokenization projects from initial assessment to implementation.

  1. Corporate structuring Company formation and cross-border business setup.
  2. Financial regulations Application preparation and regulator-facing documentation.
  3. Compliance & Governance AML/CTF frameworks and post-authorisation support.

What we handle

  • w assessment Project assessment
  • w structuring Structuring & Classification
  • w documentation Documentation
  • w implementation Implementation support
Maksim Gasanbekov

Maksim Gasanbekov

Partner, Head of Sales (Crypto and Blockchain)

maksim@gofaizen-sherle.com

Project Timelines

Set your launch date after checking which reviews your business needs.

  • Company Incorporation

    You have 20 working days after reserving the name to complete incorporation, including filing signed consents.

  • FSPR Checks

    Required criminal-history checks take 2–5 working days after payment.

  • Separate Decisions

    Separate authorizations and bank reviews follow their own schedules.

New Zealand Cryptocurrency Regulatory Framework

The Companies Office handles incorporation under the Companies Act 1993 and administers FSPR under the Financial Service Providers (Registration and Dispute Resolution) Act 2008. Incorporation creates the company. FSPR registration records the financial services it provides. An exchange that converts cryptocurrency for customers may provide a value transfer service and should check whether it must register.

Under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, reporting entities must build their written AML/CFT program around the risks of their own operations. For a payment or exchange business, that means looking at how customers fund transactions, where the money goes and which transfers warrant closer scrutiny.

FMA assesses token rights and platform activities under the Financial Markets Conduct Act 2013. An exchange that lists tokens qualifying as financial products may need a market operator license. Accepting repayable customer funds outside a genuine trust arrangement may also trigger deposit-taking rules overseen by the Reserve Bank of New Zealand.

Current Regulatory Status

LawWhat It Means for the Business
Companies Act 1993New Zealand companies need a qualifying director and physical registered addresses.
Financial Service Providers (Registration and Dispute Resolution) Act 2008Assess FSPR eligibility and retail dispute scheme requirements.
Anti-Money Laundering and Countering Financing of Terrorism Act 2009Reporting entities must implement the required controls.
Financial Markets Conduct Act 2013Check product classification, licensing and disclosure where applicable.

Ongoing Compliance Obligations

Plan for annual filings and applicable controls.

  • FSPR. Confirm your registered details and services annually and keep required information current.
  • AML/CFT. A reporting entity needs a compliance officer and a written risk assessment and program. Monitor relationships and verify customer and beneficial owner identities through customer due diligence (CDD). Check source of funds or wealth where enhanced CDD requires it. Keep AML records for at least five years, with the start date depending on the record type.
  • Travel rule. Since June 1, 2024, relevant virtual-asset transfers have required accompanying information. Duties depend on the role and counterparty, including for some transfers below NZD 1,000.
  • Reporting and audit. Submit suspicious activity reports when suspicion arises regardless of value, file prescribed transaction reports when their separate triggers apply and meet annual AML reporting duties. Arrange an independent audit every three years, or four if DIA notifies you, and whenever DIA requires one.

The reporting entity remains responsible for outsourced compliance work. Missed controls and unlicensed activities can trigger enforcement.

Taxation

Inland Revenue (IRD) treats cryptoassets as property. Income from selling, trading or exchanging them is generally taxable. Most companies pay income tax at 28% of taxable profit. Buying and selling qualifying cryptoassets is excluded from goods and services tax (GST). Check the treatment of services, non-fungible tokens (NFTs) and mining separately.

The Crypto-Asset Reporting Framework (CARF) requires in-scope reporting crypto-asset service providers with a New Zealand connection to collect reportable data from April 1, 2026, and retain records for seven years.

Local Connection, Retail Clients and Market Access

The overseas FSPR route excludes providers with only offshore clients or, for overseas providers, only New Zealand wholesale clients.

If you must join a dispute resolution scheme (DRS), record membership on the FSPR within ten working days of registration.

Check local rules before marketing to or accepting customers abroad.

Confirm Applicability Before Launch

Confirm who holds customer funds or keys, which company contracts with customers and whether the payment or token creates a repayable balance or investment right. Give the bank or payment partner a flow-of-funds diagram, ownership information and relevant registration or license records.

Frequently Asked Questions

Is there a cryptocurrency license in New Zealand?

No. New Zealand has no general cryptocurrency license. Depending on the services it offers, a crypto payment business may need to register as FSP and comply with AML/CFT requirements. A separate license may be required for certain activities, such as operating a financial product market.

Does FSPR registration cover overseas markets?

No. FSPR registration confers no overseas authorization.

Is crypto income always taxed at 28%?

The 28% rate applies to most companies. Individuals follow separate income tax rules.

Do stablecoins always need an FMA license?

Check the token’s rights and the services performed. Licensing is assessed individually.

When does a dispute resolution scheme apply?

Retail financial services generally require membership in an approved scheme, subject to statutory exceptions. The scheme handles customer complaints.

Must a director live in New Zealand?

A director who lives in Australia can qualify. Provide the Australian Company Number (ACN) of the company they direct.

How long does the application take?

The total varies with review and follow-up. Unfinished online applications expire 30 working days after you start them.

Will registration secure a bank account?

No. The bank decides after its own due diligence.

Does the Travel Rule cover self-hosted wallets?

DIA guidance excludes transfers without another virtual asset service provider from wire-transfer rules. CDD can still apply to business relationships, occasional transactions of NZD 1,000 or more, linked transactions or suspicion.

Can the program designer audit it?

The auditor must be appropriately qualified and independent of developing the risk assessment or establishing, implementing or maintaining the AML program.

When is the first CARF report due?

In-scope providers must report by June 30, 2027, for April 1, 2026, through March 31, 2027.

Client Testimonials

Trusted by Industry Leaders

Gofaizen & Sherle has successfully implemented all the tasks related to the settlement of legal part (company formation and VASP license application) of our exchange whitebit.com.

whitebit logo Vladimir Nosov CEO WhiteBIT
Axstron Finance Europe UAB;  Axstron Finance LLC Case study

Axstron Finance Europe UAB; Axstron Finance LLC

Services Provided: End-to-end support with company share transfers in Lithuania and the USA (Montana), corporate account opening, AML/KYC policy development, regulatory compliance for FNTT and FinCEN, MICA licensing advisory, HR recruitment for C-level and AML roles, and payroll accounting services.

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Mark Paat
Mark Paat
Associate, Consultant
Maksim Gasanbekov
Maksim Gasanbekov
Partner, Head of Sales (Crypto and Blockchain)
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