No. An FSPR entry is a registration, not a licence: the Companies Office says it "does not mean that you are licensed or regulated in New Zealand". The word crypto appears nowhere in the Companies Office's list of services that need an FMA licence. Registration is still mandatory where it applies - and a provider whose clients are all offshore cannot register at all.
The four numbers that decide it
Operators arrive at the Financial Service Providers Register expecting New Zealand's version of a VASP licence. The difference bites in the two places least likely to be checked: what you may say about the registration, and what removes you from it. The same two-regimes question comes up in Australia, where AUSTRAC registration and an AFSL are different things. If you are still choosing, start at choosing a licence or the fintech licence comparison.
If you want this read against your own model, send us where your clients are and who holds the assets, and we will tell you what we would check first: Telegram @fever23.
Key takeaways
- The Companies Office's list of services that require an FMA licence contains no category named for crypto.
- The regulator's own sentence: registration "does not mean that you are licensed or regulated in New Zealand".
- You cannot register at all if every client is offshore, or if you are an offshore provider serving only wholesale New Zealand clients.
- Registering from overseas means expecting 10 New Zealand resident clients and NZ$10,000 of transactions with them.
- A registered-but-not-licensed provider that names the registration on its website must carry a prescribed disclaimer; breaching that can itself get you deregistered.
On this page11 sections
What is the Financial Service Providers Register?
The FSPR is New Zealand's public register of the businesses and individuals providing financial services there, kept by the Companies Office. Its Companies Office guidance is blunt about what appearing on it signifies:
Being registered as a financial service provider does not mean that you are licensed or regulated in New Zealand. It also does not represent any sort of official endorsement of an individual, business or organisation.
That is the ceiling on what an FSPR entry proves. It is no optional formality, though: the same guidance states that providing financial services without a current registration can mean a fine or imprisonment.
Which services need an FMA licence, and which do not?
The Companies Office's list is by category of financial service: managers of registered schemes, independent trustees of restricted schemes, DIMS providers, derivatives issuers, providers of prescribed intermediary services, financial advice providers, operators of financial product markets, FMC supervisors, consumer credit providers, financial institutions and benchmark administrators. Banks, insurers and non-bank deposit takers go to the Reserve Bank.
So what does a registered crypto business hold here? An FSPR registration and, where it applies, reporting-entity status under the anti-money-laundering regime - those are the two obligations this guidance puts in front of you, and neither is a permission to trade. Operating an exchange, custodying crypto assets and providing wallet services appear nowhere on the licensing list by name; whether an exchange falls under "operating a financial product market" turns on whether what it trades is a financial product, which this page does not settle. For the custody test, see when a wallet needs a custody licence.
Crypto derivatives: where FMA licensing can apply
Two entries on that list could touch a crypto venue: derivatives issuers, and operating a financial product market. If what you offer is structured as a derivative rather than spot trading or custody, the licensing question is live and the registration question is not the one that decides it. Which side a product lands on is a legal characterisation of the product, not a function of how it is marketed. See which licence a crypto exchange needs.
Who must register, and who is barred from registering?
Three triggers make registration compulsory: providing financial services to persons in New Zealand above a minimum business threshold; being an AML/CFT reporting entity that provides financial services; and being licensed, or required by another Act to be licensed, for a specific service. The Companies Office's rules for registering from overseas also set out who cannot register at all.
Who must register, and who is barred from registering
| Your situation | The register's rule |
|---|---|
| All clients offshore | Cannot register |
| Offshore provider serving only wholesale clients in New Zealand | Cannot register |
| No place of business in New Zealand and no promotion to New Zealand clients | No registration needed, unless otherwise required to be licensed |
| Serving retail clients in New Zealand with no local place of business | Must register |
The rules turn on where your clients are, whether you have a place of business in New Zealand and whether you promote to New Zealand clients. The entity side is in local substance requirements.
What is the minimum business threshold for New Zealand FSP registration?
Registering from overseas means confirming you expect to clear a minimum annual business threshold: 10 New Zealand resident financial services clients, and NZ$10,000 of financial services transactions in total with them. Half of that - 5 clients and NZ$5,000 - must be achieved in the first 6 months after registering. Read alongside the bar on registering with solely offshore clients, the threshold asks for real New Zealand business.
That 6-month half-threshold is the only checkpoint the guidance states, so we will not invent a consequence for a later shortfall that the Companies Office has not published.
How do you register a New Zealand FSP?
You declare services, not an industry. The Companies Office requires that "you must declare the services you will be offering" and that "once registered, you need to keep this information up to date"; the full list sits in section 5 of the Financial Service Providers (Registration and Dispute Resolution) Act 2008. Those declaration categories are a separate list from the licensing one, and this page does not reproduce them; which class a given exchange, wallet or custody model falls into is a legal characterisation of that business rather than something read off a list. The sequence, per the Companies Office's own guide to preparing to register:
- Confirm you are not barred - an all-offshore client base cannot register - and that you expect to clear the threshold.
- Apply online: you need a RealMe login and an online account with the Companies Office.
- Declare each class of service you will provide; an FMA levy applies for each class when you file your annual confirmation.
- Declare whether you are an AML/CFT reporting entity. While its systems are being updated, the Companies Office asks registrants to "only select Department of Internal Affairs".
- If you serve retail clients you will in most cases need to join an approved dispute resolution scheme, and must update the FSPR with those details within 10 working days of registering.
- File an annual confirmation every year.
How much does New Zealand FSP registration cost?
These are the government's own charges, not service fees, from the Companies Office schedule of fees and levies, in effect since 1 July 2022.
What the government charges, in effect since 1 July 2022
| Charge | Excluding GST | Including GST |
|---|---|---|
| Application fee to register | NZ$300 | NZ$345 |
| FMA levy on registration | NZ$600 | NZ$690 |
| Criminal history check, per person | NZ$11.30 | NZ$13 |
Then it recurs: NZ$75 plus GST for the annual confirmation, on top of an FMA levy for each class of service declared. See also annual obligations and withdrawal.
What may you say about being registered?
Less than most registered providers assume. The Financial Service Providers (Registration) Regulations 2020 limit how a provider may promote its registration, and require the prescribed disclaimer statement on the website of a provider that is registered but not licensed, is not a financial adviser or consumer credit provider, and refers to its FSPR registration or its New Zealand dispute resolution membership. Copy calling the entity "regulated in New Zealand" on the strength of an FSPR entry is the exact claim the register's own guidance contradicts.
Checking a counterparty's claim rather than making one? See how to check a crypto licence is real, which walks the registers.
Who supervises the AML/CFT side now?
From 1 July 2026 there is one supervisor: the Department of Internal Affairs. The Companies Office states that from that date the DIA is the only supervisor of reporting entities under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. Before the change there were three possible supervisors depending on the financial service.
The obligations sit on the Department's virtual asset service provider page: a money-laundering and terrorism-financing risk assessment under section 58 of the AML/CFT Act, then an AML/CFT programme built on that assessment under section 56. VASP-specific rules are not a 2026 invention: the Department's VASP guidance dates from March 2020, and its July 2024 guidance covers wire transfer and prescribed transaction requirements - see the travel rule by route. Not every registered provider is a reporting entity, but the Companies Office adds that failing those obligations could result in a significant fine or even imprisonment.
Writing on the day the change took effect, Leanne Chew, John Anayi and Sarah Waller of MinterEllisonRuddWatts noted that "Stage 1 includes clarifying the treatment of virtual asset transfers and introducing specific AML/CFT compliance obligations for virtual asset service providers (VASPs)".
What gets you deregistered?
The grounds are set out in section 18(1) of the Financial Service Providers (Registration and Dispute Resolution) Act 2008. The Companies Office lists, among others:
- failing to file the annual confirmation;
- failing to join a dispute resolution scheme within 10 working days of registering or being engaged by a financial advice provider;
- a registration accepted on the basis of false or misleading information;
- dishonoured or reversed fee payments;
- a direction from the FMA or the Financial Advisers Disciplinary Committee.
The procedure is the part worth planning around. Where the Registrar initiates removal you have 20 working days to object; where the FMA or the FADC directs it, you cannot object and removal is immediate. Reregistration, where available, has to happen within 60 calendar days.
Frequently asked questions
Will a bank or payment partner accept an FSPR number as proof that we are regulated?
In our view, treat it as unlikely to survive diligence: a counterparty who reads the Companies Office guidance reads the same sentence you do, that registration does not mean you are licensed or regulated. See banking after the licence.
Does being on the FSPR make us an AML/CFT reporting entity?
No, and the relationship runs the other way. Reporting-entity status comes from the AML/CFT Act, not from the register, and not every registered provider is a reporting entity. Being a reporting entity that provides financial services is itself one of the three triggers that make registration compulsory.
Is buying an already-registered New Zealand entity quicker?
What you buy is an application history, not a blank slate. The application names every director, controlling owner - whoever beneficially owns 50 per cent or more - and senior manager, and any of the three may need a criminal history check. Directors are run against the banned directors and managers database: someone prohibited from being a director in New Zealand or Australia "cannot be associated with, or registered as, a financial service provider". Where a change of owner needs approval: shareholder tests.
Where to start
Send us your business model, where your clients are and who holds the assets, and we will tell you which of these rules bite first and what we would check before New Zealand is on your list. New Zealand is one of four licensing routes CryptoLicense (CL GLOBAL SDN BHD, 1421939-T) handles; entity details are on entity proof. This page describes published New Zealand legislation and regulator guidance. It is not legal advice, no application or registration can be guaranteed, and the decision and the timing belong to the regulator.
Part of a series: the full guide is at choosing a licence.