Insights—Licence applications · SEC

Which SEC digital asset licence fits your business model? A decision guide for founders

Start from what your business does with client assets and client orders — not from what you call the product.

October 2026 · 6 min read

Start from activities, not labels

Founders often describe their product in market terms — an app, a platform, a wallet. The licence follows from what the business actually does: whether it matches orders, acts for clients, trades as principal, holds client assets, offers tokens or manages portfolios.

Five questions that narrow the field

  • Do you bring buyers and sellers together on your own venue? That points towards an exchange.
  • Do you route or execute client orders elsewhere? That points towards a broker.
  • Do you buy and sell against clients on your own account? That points towards a dealer.
  • Do you hold client digital assets or keys? That points towards a custodial wallet provider.
  • Do you screen and offer tokens to investors, or manage and advise on portfolios? That points towards an ICO portal, or a fund manager or advisor.

One model, more than one licence

Many business models combine activities. A trading app that also holds client assets may need more than one licence, or an arrangement with a licensed partner. Deciding this early shapes the company structure, capital and systems.

What to prepare before the first meeting

A one-page description of the business model, the intended shareholders and key people, and the client journey from onboarding to withdrawal. That is enough to confirm the licence path in an assessment.

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