Fintech hubs, their current state and opportunities for business
If work in payments long enough, you've probably noticed how dramatically the conversation around jurisdictions has shifted over the past few years. The choice used to revolve around handful static options: need to operate in Europe — go to Lithuania; eyeing Asia — look at Singapore; want lighter-touch regulation — Malta or Estonia immediately stood out from the crowd.
Today that map looks different, and not just because the old options have gotten more expensive or restrictive (though that's true too), but because new players have emerged offering genuinely serious alternatives. The world is moving toward segmentation, where the US and EU are no longer the default "go to" jurisdictions for every use case, but simply two of the options available to modern businesses. This creates competition and potentially better terms for startups.
Let's break down what's actually happening right now.
Mature hubs are still relevant — just not what they used to be
The UAE remains the most popular destination for companies from the CIS, Asia, and the Middle East — the combination of zero tax, English common law, and a regulator that genuinely wants to attract business never goes out of style. But it's important to understand that Emirates are three distinct regulatory worlds under one roof, and choosing between them has real practical consequences.
DIFC and ADGM are international financial centers with their own legal systems and banking access, operating on English law principles — they look more like London inside the Emirates than a local regulator. The Central Bank (the third option) operates under its own stricter framework but gives access to the local retail market. For payment companies, ADGM licenses are most in demand; for crypto, VARA has become the de facto standard since major players moved in.
The key nuance that usually doesn't make it into the polished licensing presentations is banking. Account access for free zone companies can be surprisingly difficult, especially if the business involves crypto or high-risk merchants. You can have the license, but a functioning bank account is a separate challenge — and one that's often underestimated from the outset.
Singapore and MAS were long synonymous with the premier Asian license: the regulator's reputation opens doors to banks across Asia better than anything else in the region. Since August 2024, MAS has introduced additional requirements for all new applicants: a mandatory legal opinion mapping the business model to regulated activities, and an independent external audit assessment for crypto-related operations. In June 2025, the regulator closed the door for crypto providers looking to serve exclusively foreign clients without a Singapore license.
All of this is shifting the view — Singapore is now worth considering only if you have an Asian market focus and the resources for a longer and more expensive licensing process than a few years ago. A license for the whole world? That's definitely not what Singapore is about anymore.
Within Europe, Lithuania remains the most popular gateway into the EU for fintech — relatively fast, predictable, and offering the ability to operate across the entire EU. The Netherlands runs in parallel for larger players. For the crypto sector, the picture has changed with MiCA: a CASP status under the unified European framework is now required, though regulatory approaches still vary. Some countries historically scrutinize each application more carefully and maintain greater distance from applicants.
Poland's situation within the EU is one of the most illustrative: the country still hasn't adopted local crypto regulation, despite over a thousand companies waiting. Just a few years ago Poland was considered a soft jurisdiction — which attracted plenty of interested projects to its VASP license. Now the country is lurching between extremes: from a tolerant approach, Poland is attempting to shift to strong oversight of crypto operators. Many expected things to continue along the previous track, but the odds of that happening now are genuinely low.
Rising alternatives: where the regulator works for you
There are a number of jurisdictions that weren't taken seriously a few years ago and are now becoming real options for launching a fintech business.
Georgia is perhaps the clearest example of how a small country can, in a relatively short time, build a functioning fintech infrastructure — when the government is actually committed to that outcome. The National Bank of Georgia has established a clear framework for PSP and VASP licensing with transparent requirements and reasonable timelines. Open banking has been available to non-bank providers since 2023; a national instant payment system launches in 2026.
On the practical side for PSPs: there are no minimum capital requirements, but you need a local director present in the country for at least 14 days per month; approval from the National Bank after filing takes around 30 days; but crypto requires a separate VASP license.
For companies from CIS region the appeal is obvious: low capital entry threshold, and local banks are genuinely willing to work with fintech clients. The Bybit CEO's meeting with Georgia's Prime Minister to discuss developing the digital asset ecosystem wasn't a random PR move — it was a political signal that the country is competing for this business at the highest level. That said, a Georgian license doesn't give EU access. It is not a tool for reaching European customers. Georgia is an operational base for working in the CIS and the Middle East — a place to start a fintech business.
Kazakhstan built Astana International Financial Centre on the DIFC model — with its own English law-based legal system, a separate regulator (AFSA), and an independent court. For payment companies, the key license is the Money Service Operator, with a minimum capital requirement of $200,000 — quite modest. Residents of the AIFC also benefit from tax incentives running through 2066.
The practical value of a Kazakh license is primarily access to the Central Asian market, which is growing fast while remaining significantly underserved by fintech infrastructure. Investors from the UAE and Saudi Arabia engage here more readily than in other Central Asian jurisdictions, precisely because the structure feels familiar.
Bahrain remains in Dubai's shadow and few take it seriously, but from a regulatory standpoint it has a genuine structural advantage: the Central Bank of Bahrain is the single regulator for the entire financial sector, with no free zone/mainland split — which in practice means a shorter path from sandbox to full license.
Bahrain launched its regulatory sandbox in 2017 and open banking in 2018 — ahead of most of its neighbors. In 2025, the Central Bank introduced a framework for licensing stablecoin issuers. The number of fintech companies in the country has grown from 25 to over 100 in just a few years, which speaks to real competitive traction in the region. If you need a quality license without paying Dubai prices — this is worth a look.
Hong Kong deserves a mention too. Not a new player, but its return as a hub for international finance warrants separate attention. In 2026, Hong Kong overtook Switzerland in cross-border capital placement volumes for the first time, and continues to grow. What makes Hong Kong unique is that it's the only jurisdiction simultaneously integrated into the global financial system and offering real access to the Chinese market. For companies with an Asian focus, it's another option worth considering — especially as Singapore, the obvious alternative, has gotten more complicated.
Looking at the overall picture, a pattern emerges that explains why things are changing so quickly: states have started treating fintech as a tool of economic policy and growth, and regulators are working with businesses rather than against them — because they need jobs, taxes, investment, and international visibility. This is fundamentally different from Europe, where the regulator's primary focus is consumer protection, or the US, where fragmented state-level regulation creates operational headaches for any scaling effort. The upshot: you can now choose a license that fits your goals and your budget, without being forced into the EU if its requirements are too high and your business objectives don't strongly align with them.
How to choose in practice
The biggest mistake when selecting a jurisdiction is choosing based on “where it's cheapest to set up.” A license is not a one-time investment — it's an infrastructure decision that shapes your operational reality for years. That's why it's worth working through the key factors that will define your licensing requirements.
First, geographic business focus. If your merchants or users are in the EU, you need a European license with passporting rights — no Georgian or Dubai option replaces that. If the focus is the CIS, the Middle East, or Asia, regional hubs deliver comparable results for less money and usually much faster.
A bank account is non-negotiable, as a license without a working correspondent account is essentially just paper — it gives you no operational capacity. Before filing anything, understand which banks actually work with companies from your chosen jurisdiction with your type of business, and how long account opening realistically takes. Don't overlook director and UBO requirements either — checks have tightened everywhere, and it's far better to assess potential issues early than at the point of rejection.
Before rushing to buy a ready-made license, take the time to evaluate your specific situation and make a considered decision — one whose effectiveness will drive your business for years to come. A lot changes quickly, which makes it important to assess trends and the capital available for the project. If the cost doubles in the next six months, are you prepared to proceed? Start by mapping out the core services requiring a license, the operational constraints, and the realistic growth you could achieve in the first two years. Once that roadmap exists, the right direction for your specific project usually becomes clear.
