Knowledge Base
Practical reads on crypto, AI, and licensing
Articles and alerts written by the Licentium team. New posts every couple of weeks.
Indonesia's MoF Regulation 108/2025 Activates Crypto-Asset Tax Reporting from 2026
Indonesia's Ministry of Finance issued Regulation No. 108 of 2025 (MoF 108) implementing the Crypto-Asset Reporting Framework. The rule sets statutory reporting duties for Crypto Asset Service Providers and brings payment service providers and licensed e-wallet operators under the financial information reporting scheme. First reporting covers the 2026 calendar year, due to the Directorate General of Taxes by 30 April 2027.
Colorado Legislature Passes SB 189 Repealing and Replacing the Colorado AI Act, 12 May 2026
On 12 May 2026, the Colorado General Assembly passed SB 189, which repeals the Colorado Artificial Intelligence Act (SB 24-205) and replaces it with a disclosure-focused statute covering automated decision-making technology. The bill drops the duty of care, risk management programmes, and impact assessment duties. Governor Polis is expected to sign. The new statute takes effect on 1 January 2027.
Cayman Islands Brings Tokenised Funds Acts into Force, 24 March 2026
The Cayman Islands' Mutual Funds (Amendment) Act, 2026 and Private Funds (Amendment) Act, 2026 came into force on 24 March 2026. The Acts add statutory definitions and operating requirements for tokenised mutual funds and tokenised private funds. The Cayman Islands Monetary Authority (CIMA) supervises tokenised vehicles under the same regime that applies to traditional funds.
EU Council and Parliament Reach Provisional Agreement on AI Act Digital Omnibus, 7 May 2026
On 7 May 2026, the Council of the European Union and the European Parliament agreed provisional amendments to Regulation (EU) 2024/1689 (the AI Act). The deal postpones high-risk AI compliance dates, defers watermarking duties to December 2026, and adds a prohibition on non-consensual intimate imagery generators. Formal adoption is pending.
European Commission Publishes Draft AI Act Article 50 Transparency Guidelines, 8 May 2026
On 8 May 2026, the European Commission published draft Guidelines on transparency obligations under Article 50 of Regulation (EU) 2024/1689 (the AI Act) and opened a public consultation. The draft clarifies disclosure duties for chatbot operators, deepfake creators, emotion-recognition system deployers, and synthetic content producers. Comments close on 3 June 2026.
Pennsylvania sues Character.AI over chatbot impersonation of licensed psychiatrist
On 5 May 2026 the Pennsylvania Department of State filed suit against Character Technologies, Inc., alleging that AI chatbots on its platform engaged in the unauthorized practice of medicine. State investigators found a chatbot named Emilie offered mental health diagnoses, claimed Pennsylvania licensure with a fake licence number, and stated it could prescribe medication. The Commonwealth seeks a preliminary injunction.
UK ICO opens consultation on automated decision-making after Data (Use and Access) Act
The Information Commissioner's Office launched a consultation on draft guidance for solely automated decision-making under the Data (Use and Access) Act 2025. The Draft Guidance is the ICO's first detailed reading of how the DUAA changes Article 22 UK GDPR. The consultation closes on 29 May 2026. A statutory code of practice on AI and ADM is expected later in 2026.
FinCEN and OFAC propose AML, CFT and sanctions rules for stablecoin issuers
On 8 April 2026 the US Treasury's FinCEN and OFAC issued a joint Notice of Proposed Rulemaking implementing AML, countering the financing of terrorism and sanctions compliance obligations for permitted payment stablecoin issuers under the GENIUS Act. The Proposed Rule treats issuers as financial institutions under the Bank Secrecy Act. Comments are due 9 June 2026. Final rules would take effect twelve months after issuance.
EU lawmakers reach political agreement to delay AI Act high-risk obligations
On 7 May 2026 the Council of the EU and the European Parliament reached political agreement on the Digital Omnibus on AI. Annex III high-risk obligations are pushed to 2 December 2027. The Article 50 transparency grace period for AI-generated content shrinks to three months ending 2 December 2026. Member states have until 2 August 2027 to set up regulatory sandboxes.
India's Promotion and Regulation of Online Gaming Act 2025 Took Effect on 1 May 2026
India's Promotion and Regulation of Online Gaming Act, 2025 came into force on 1 May 2026. The Ministry of Electronics and Information Technology notified the Promotion and Regulation of Online Gaming Rules, 2026 on 22 April 2026. The Act bans online money games of skill, chance, and mixed formats. The Act recognises e-Sports as legitimate competitive sport. Operators serving Indian users must withdraw real-money offerings or face penalties.
Virginia, Kentucky, and Wisconsin Enact Virtual Currency Kiosk Licensing Laws
Three US states enacted virtual currency kiosk laws in April 2026. Virginia House Bill 665, Kentucky Senate Bill 189, and 2025 Wisconsin Act 226 each impose licensing duties on kiosk operators. The laws layer in transaction limits, customer disclosures, and fraud protections aimed at scams targeting older adults. Effective dates and limit thresholds differ across the three regimes. Operators with multistate footprints must reconcile diverging compliance calendars.
Federal Court Pauses Enforcement of Colorado AI Act on April 27, 2026
On 27 April 2026, Magistrate Judge Cyrus Y. Chung of the U.S. District Court for the District of Colorado paused enforcement of the Colorado Artificial Intelligence Act, Senate Bill 24-205. The order followed a suit filed by xAI Corp. seeking a preliminary injunction. Attorney General Phil Weiser cannot pursue alleged violations of the 2024 statute within 14 days of the court ruling on that motion. The statute's 30 June 2026 implementation date remains scheduled.
New York AG Secures $5 Million Settlement from Uphold Over CredEarn Yield Product
On 29 April 2026, New York Attorney General Letitia James announced a settlement with Uphold HQ Inc. The crypto platform must pay over $5 million to investors who lost money in CredEarn, the yield product issued by Cred LLC. Uphold must also register as a broker with the Office of the Attorney General and adopt new third-party diligence requirements. The action rests on findings that Uphold misleadingly promoted CredEarn before Cred collapsed in 2020.
Australia: 30 June 2026 deadline for digital asset firms to apply for an AFS licence
ASIC has set 30 June 2026 as the cut-off for digital asset financial service providers in Australia to apply for an Australian Financial Services licence, or risk operating in breach of the law.
Federal court pauses enforcement of the Colorado AI Act
A federal court has stayed enforcement of Colorado's SB 24-205 weeks before its 30 June 2026 effective date, leaving one of the country's most far reaching state AI laws on hold.
South Africa's prediction markets sit in a regulatory grey zone
An ENS analysis maps how prediction market contracts in South Africa cut across crypto regulation, exchange control and the law of derivatives, exposing a gap that regulators have yet to close.
FCA Publishes Policy Statement PS26/7 on Fund Tokenisation via DLT, United Kingdom, April 2026
The Financial Conduct Authority (FCA) published Policy Statement PS26/7: Progressing Fund Tokenisation on 30 April 2026, along with final rules amending the FCA Handbook. PS26/7 sets out guidance for asset managers on how to use distributed ledger technology (DLT) within the FCA's existing rules when tokenising funds, and introduces an optional Direct to Fund (D2F) dealing model. The policy statement and rules are operative with immediate effect upon publication. The controlling authority for
FCA Opens Pre-Application Support for UK Cryptoasset Authorisation, PASS from 11 May 2026
The Financial Conduct Authority (FCA) announced on 30 April 2026 that cryptoasset firms preparing for the new Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (the Crypto Regime) may request pre-application meetings via its Pre-Application Support Service (PASS) starting 11 May 2026. Pre-application meetings are free of charge and give firms the opportunity to discuss their regulatory plans and ask questions before submitting a formal authorisation application or
India Notifies Promotion and Regulation of Online Gaming Rules 2026, Effective 1 May 2026
India's Ministry of Electronics and Information Technology (MEITY) notified the Promotion and Regulation of Online Gaming Rules, 2026 (the Rules) on 22 April 2026, pursuant to the Promotion and Regulation of Online Gaming Act, 2025 (the Act). The Rules took effect from 1 May 2026. The Act was enacted by Parliament in August 2025 and replaced, to the extent of conflict, state-specific gambling legislation and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code)
UK Supreme Court Overrules Aerotel Test for AI Patent Eligibility in [2026] UKSC 3
The Supreme Court of the United Kingdom delivered judgment in Emotional Perception AI Limited (Appellant) v Comptroller General of Patents, Designs and Trade Marks (Respondent) [2026] UKSC 3 on 11 February 2026. The Court allowed the appeal unanimously, set aside the UKIPO's decision refusing the patent application, and remitted the matter to the UKIPO for assessment of novelty and inventive step. The decision has immediate operative effect and withdraws the UKIPO's 30 January 2025 guidelines
MAS Consults on Prudential Treatment of Cryptoassets on Permissionless Blockchains, Singapore, April 2026
The Monetary Authority of Singapore (MAS) published Consultation Paper P009-2026 on 17 April 2026, proposing a framework for the prudential treatment of cryptoassets held on permissionless blockchains. The consultation is open until 18 May 2026 at 11:59 PM. The paper addresses the classification of permissionless-blockchain cryptoassets for capital adequacy, credit risk, and liquidity risk purposes under Singapore's banking and financial institution regulations. MAS proposes to allow banks to
Australia Enacts Corporations Amendment (Digital Assets Framework) Act 2026, ASIC Issues Implementation Roadmap
The Corporations Amendment (Digital Assets Framework) Act 2026 (the DAF Act) passed the Australian Parliament on 1 April 2026, received Royal Assent on 8 April 2026, and will commence on 9 April 2027. On 20 April 2026, the Australian Securities and Investments Commission (ASIC) published its implementation roadmap setting out the regulatory guidance and operational standards it will develop over the 18-month transition period. The DAF Act and the ASIC roadmap are operative in the preparatory
UK FCA Applies Existing Regulatory Rules to Artificial Intelligence in Financial Services, 2024
The UK Financial Conduct Authority (FCA) published its formal approach to artificial intelligence in financial services in 2024, declaring that it would not introduce a bespoke AI-specific rulebook. The approach is operative: the FCA applies its existing Principles for Businesses, Consumer Duty, operational resilience standards, and Senior Managers and Certification Regime (SM&CR) accountability rules to AI systems deployed by regulated firms. The FCA simultaneously launched an AI Lab to
California Governor Newsom Issues Executive Order N-5-26 on AI Procurement Standards, March 2026
California Governor Gavin Newsom issued Executive Order N-5-26 on 30 March 2026. The order is in effect immediately upon issuance and directs the California Government Operations Agency (GovOps) to develop a plan for new state contracting processes and best practices for AI companies seeking state contracts. The order is at the executive direction stage: GovOps must produce the procurement plan within a specified period, and no statutory changes are required. The California Department of
EU DAC8 Directive Mandates Crypto-Asset Reporting by Member State Tax Authorities from 2026
Council Directive (EU) 2023/2226 of 17 October 2023, known as DAC8, entered into force on 12 December 2023 and amended Directive 2011/16/EU on administrative cooperation in the field of taxation. Member States must transpose DAC8 into national law by 31 December 2025, with the reporting obligations applying to reportable transactions completed from 1 January 2026 onward. DAC8 is fully operative as of the 2026 reporting year, with the first automatic exchange of information between tax
US FDIC Approves Proposed Rule Implementing GENIUS Act for Payment Stablecoins, April 2026
On 7 April 2026, the Federal Deposit Insurance Corporation (FDIC) Board of Directors voted at an open board meeting to approve a notice of proposed rulemaking (NPR) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The proposed rule is at the notice-and-comment stage and will be published in the Federal Register, with public comments accepted for 60 days following publication. The proposed rule would apply to FDIC-supervised permitted payment
Colorado AI Act SB24-205 Takes Effect February 2026 as Enforcement Delayed Pending Rulemaking
Colorado Senate Bill 24-205, the Colorado Artificial Intelligence Act (the "AI Act"), entered into force on 1 February 2026 pursuant to its statutory effective date following enactment by Governor Jared Polis on 17 May 2024. The law requires developers and deployers of high-risk artificial intelligence systems to use reasonable care to protect consumers from known or reasonably foreseeable risks of algorithmic discrimination. The Colorado Attorney General stated in a court filing that the
UK High Court Continues Cryptoasset Freezing Injunction Against Unknown Persons, January 2026
On 23 January 2026, Mr Justice Waksman of the Business and Property Courts of England and Wales (Commercial Court) handed down judgment in Smithers & Anor v Persons Unknown Category 1 & Ors [2026] EWHC 207 (Comm), continuing a freezing injunction over cryptocurrencies originally granted on 13 November 2025. The claim arises from the alleged wrongful removal of cryptocurrencies held by the claimants, who were deceived into parting with the assets by unnamed primary respondents. The judgment
Ireland Court of Appeal Sets AI Disclosure Rules for Litigation Parties, March 2026
On 26 March 2026, the Court of Appeal of Ireland handed down judgment in Guerin v O'Doherty [2026] IECA 48, in which the President of the Court, Ms Justice Costello, set out guidelines on the use of artificial intelligence by parties in litigation. The judgment addresses the procedural obligations arising when AI tools assist in preparing written submissions and marks the first time an Irish appellate court has issued structured AI-use guidelines binding on parties appearing before it. The
UK Automated Decision-Making Rules Under Data (Use and Access) Act 2025 Enter Force, February 2026
The Data (Use and Access) Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026, S.I. 2026/82, brought section 80 of the Data (Use and Access) Act 2025 into force on 5 February 2026. Section 80 replaces Article 22 of the UK General Data Protection Regulation with a new four-article automated decision-making structure. The commencement is at the final, operative stage. The controlling authority is section 80 of the Data (Use and Access) Act 2025 (c. 18), which
UK Stablecoin Payments: HM Treasury Publishes Draft Amending SI to Cryptoassets Regulations, April 2026
On 21 April 2026, HM Treasury published a draft statutory instrument (SI) and accompanying policy note proposing amendments to the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. The draft SI is at the consultation stage; Treasury is inviting written responses from industry participants until close of business on 22 May 2026. No provisions are yet in force. The controlling authority is the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, made
CSA Launches Project Tokenization to Examine Distributed Ledger Technology in Canadian Capital Markets, March 2026
On March 31, 2026, the Canadian Securities Administrators (CSA) announced the launch of Project Tokenization, a formal initiative within the CSA Collaboratory, to examine how distributed ledger technology (DLT) intersects with Canada's existing securities laws. The initiative is in the active engagement phase. The CSA invited a broad range of market participants to participate in regulatory workshops, with the first workshop scheduled in Calgary on April 9, 2026, and a second in Toronto on
FDA and EMA Issue Joint Guiding Principles of Good AI Practice in Drug Development, January 2026
In January 2026, the U.S. Food and Drug Administration (FDA), through its Center for Drug Evaluation and Research (CDER) and Center for Biologics Evaluation and Research (CBER), jointly published with the European Medicines Agency (EMA) a set of ten guiding principles for the use of artificial intelligence (AI) in drug and biological product development. The document is final and published; it carries no binding legal force as a regulation but constitutes authoritative guidance from two of
CSA and CIRO Issue Guidance on Prediction Market Regulation in Canada, April 2026
On April 2, 2026, the Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) jointly issued a public notice reminding industry participants and investors of the existing regulatory requirements that govern prediction markets and event contracts in Canada. The notice is at the final, published stage and carries immediate compliance effect across all CSA jurisdictions. The controlling authority is the securities and derivatives legislation applicable
UK FCA Publishes CP26/13 Cryptoasset Perimeter Guidance Consultation, April 2026
The Financial Conduct Authority (FCA) published Consultation Paper CP26/13 ("Cryptoasset Perimeter Guidance") in April 2026, seeking public comment on draft guidance that defines which cryptoasset activities will require FCA authorisation under the new UK regulatory regime. The consultation is at the open consultation stage, with responses due by 3 June 2026. The FCA plans to publish final perimeter guidance in autumn 2026 and final rules in policy statements in summer 2026. The controlling
UK ICO Publishes Report and Draft Guidance on AI and Automated Decision-Making in Recruitment, March 2026
On 31 March 2026, the Information Commissioner's Office (ICO) published a report and draft guidance on automated decision-making (ADM) in recruitment. The ICO engaged more than thirty employers and issued written notices to sixteen organisations using ADM in hiring. Those sixteen organisations committed to implementing recommended improvements. The report and draft guidance address the full lifecycle of AI-driven recruitment tools, from CV screening to scoring of online assessments. The
Licentium: Applied Legal Research for Crypto and AI Products
Licentium is a legal-tech research and execution team for crypto, digital-asset, and AI products. We help teams classify their product, choose the right licence path, prepare filing materials, and keep operations aligned with public rules after launch.
Tokenization of Real-World Assets: Legal Challenges and Considerations
Tokenising real-world assets sits at the intersection of securities law, custody, AML, and property law. A walk-through of the technical process, the legal challenges, and the use cases driving adoption.
Understanding Utility Tokens under MiCA: Classification, Requirements, and Issuers' Obligations
MiCA defines utility tokens narrowly. This guide explains where utility tokens sit in the MiCA classification, what disclosures issuers must make, and which exemptions apply.
NFTs and Intellectual Property: A Comprehensive Legal Guide for Creators and Investors
How copyright, fair use, and licensing apply to NFTs. A practical guide for creators and investors on what they actually own when they mint or buy a non-fungible token.
A Comprehensive Guide to DAO Governance: Key Principles and Best Practices
The principles, frameworks, and best practices behind effective DAO governance. From decentralisation and transparency to multi-sig wallets and dispute resolution, with notes on jurisdictional risk.
Understanding DAO Voting Mechanisms: Challenges, Ideas, and Risks
One token one vote, quadratic, conviction, holographic. The voting mechanisms DAOs actually use, what each one optimises for, and the legal risks each one creates.
Ready to launch legally?
Book a 30-minute consultation. We'll map your licensing path and tell you exactly what's required, in plain language.