The regulatory arbitrage era is over, and the encryption exchange license plate contains a lot of gold

By Chloe, Challenger

 

Over the past decade, the logic of expansion of the encrypted currency exchange has been “user before compliance”. But this logic was completely reversed in 2026, and now what really opens the gap is the compliance dividend of license plates。

When the era of regulatory arbitrage comes to an end, how do you compete for tickets to the next round with different strategies

2026 New battlefields between exchanges: compliance Dividend

According to the annual derivatives market report published by CoinGlass in 2025, the total volume of Central Chemical Exchange derivatives traded throughout the year reached US$ 85.7 trillion, with an average of US$ 264.5 billion per day, with a high concentration of municipalities, with the shares of the first five exchanges exceeding 80 per cent. At such a market scale, no head exchange can continue to grow without a simple “lower charge” or “more currency” differentiation, as the marginal utility of these advantages is diminishing。

Market position and current ranking of five exchanges

Before entering the plate count, use the data to see the relative position of the five exchanges in 2026。

According to TokenInsight 2025 annual report, the distribution of spot market shares for the year was as follows: 42.09 per cent currency, Bybit 8.63 per cent, MEXC 8.49 per cent, Gate 8.16 per cent, Bitget 6.86 per cent, OKX 6.83 per cent, Coinbase 6.58 per cent, KuCoin 4.3 per cent

The pattern of derivative markets varies slightly. The data show that the average city was the first in the year 2025 at 34.74 per cent, with OKX ranked second at 15.06 per cent, Bybit 12.95 per cent, Bitget at 11.27 per cent, and MEXC and Gate at 10.58 per cent and 8.25 per cent, respectively。

These two sets of data show that, in addition to the absolute advantage of currency in spot and derivative markets, the shares of the other four were in fact glued. When the market size is scaled up and the distribution of shares stabilizes, those who have access to licences in key markets have the opportunity to leap up in the next shuffle。

It is noteworthy that these five head exchanges also maintain a leading position on the dimensions of transparency in compliance. According to the Encrypted Asset Data Platform RootData, in the eighth issue of the Encoded Currency Exchange Transparency List (Equities) published by the Web3 Asset Data Platform RootData, Binance, OKX, Bybit, Gate and Bitget continue to be in the top five positions, in a highly consistent pattern with the market share of spot and derivatives. The list continues to focus on the growth of equity assets in the encryption exchange。

BEN: Absolute lead compliance shift

Cheonan is the only player on this list who does not need to worry about market share, but is the one who has the greatest regulatory pressure。

Between 2023 and 2024, the United States of America experienced massive regulatory fines and reconciliations, which fundamentally changed the corporate strategy. According to Nikkei Asia, in March 2026, the head of the Horn of Africa and the Pacific region, SB Seker, stated that his country planned to obtain five new Asian licences in 2026, bringing the number of licensed jurisdictions worldwide to more than 20。

By the beginning of 2026, it had held regulatory approvals in Asia from Australia, India, Indonesia, Japan, New Zealand and Thailand, and was about to enter the picture by acquiring ownership of Gopax in Korea。

The global scale of the coin is itself producing narratives of compliance, which, according to its 2025 annual report, account for more than 300 million registered users worldwide and more than $7.1 trillion in cash transactions throughout the year. Under this scale, currency is banned in any single country, affecting not only local users but also the entire OTC market and stable currency liquidity. In many markets, as unlike other exchanges, it acquires licences through the acquisition of locally held entities (e.g. Gopax) rather than from zero applications, which can shorten the time horizon, but also means that it must take over the historical burden of the buyer。

The compliance narrative data for 2025 will be updated directly in its compliance update report, and the ratio of direct and indirect financial flows related to sanctions to total transactions decreased from 0.284 per cent in January 2024 to 0.009 per cent in July 2025, a decrease of 96.8 per cent。

Bitget: Backwards from scratch

Bitget is the last of the five exchanges to start laying the plates, but the speed and breadth of the plates are quite positive. According to a public letter published by Bitget in April 2025, signed by the Chief Justice Hon Ng, Bitget had "over eight licence plates". By early 2026, Bitget had regulatory registers in Europe, Asia, the Middle East, Latin America and Oceania, including Australia, Italy, Poland, El Salvador, the United Kingdom, Bulgaria, Lithuania, the Czech Republic, Georgia and Argentina。

On the Asian side, Bitget completed the registration of VARA (Dubai Virtual Assets Control Authority) by the end of 2025, authorized it to provide supervised virtual asset services from Dubai headquarters, also obtained digital asset plates in Georgia and used the Tbilisi Free Zone as a hub for Eastern European expansion。

In terms of licensing strategy, Bitget follows a “widening first, depth later” route, which is mostly registered in Europe with VASP, rather than with MiCA full CASP; in Asia, full licences have not yet been obtained from Japan, Hong Kong, and Singapore, the three most gold-bearing markets. Perhaps the challenge for Bitget is that when the number of license plates reaches a certain scale, the market starts asking for “quality”。

Bybit: The swing between defeat and breakthrough

Bybit is the most twisted path of the five. In May 2024, Bybit withdrew from the Hong Kong market due to regulatory pressure from the HKSRC and its associated entity Spark Fintech Limited formally withdrew its licence application. By the end of 2025, Bybit announced that it would phase out its services to Japanese residents in 2026 and requested affected users to complete their identification by 22 January 2026, otherwise it would be considered a Japanese resident and its use would be restricted. For its part, the Singapore Monetary Authority MAS required unlicensed digital token service providers to cease operating overseas and Bybit to cease operating in Singapore by June 2025。

But on the other side, Bybit took two license plates with relatively high gold in industry. In October 2025, the United Arab Emirates Securities and Commodities Administration SCA granted Bybit the first full “Virtual Asset Platform Operator's License”, covering transactions, brokering, trusteeship and French currency services in seven Emirates countries throughout the United Arab Emirates. In Europe, Bybit EU GmbH obtained its MiCAR licence plate through the Austrian Monetary Authority FMA in May 2025, which is accessible in the 29 EEA countries。

 In addition, Bybit was the largest hacker attack in the history of encryption in February 2025, with a loss of about $1.460 billion. The incident put a great deal of pressure on Bybit ' s compliance and security narrative in 2025 and was one of the triggers for the Japanese Financial Services Agency to consider requiring the exchange to raise capital reserves. The Bybit case illustrates one thing: the holding of cards is different from the holding of cards。

Gate: The silent matrix of compliance

Gate is not as visible in the Asian Chinese community as Minan and OkX, but simply looking at the details covered by the license plate, Gate’s layout is unexpectedly complete. According to the registration page published by Gate, Gate obtained regulatory registration, licence or approval in over eight jurisdictions at the beginning of 2026, including Hong Kong, Gibraltar, Malta, Japan, Australia, Bahamas, Dubai and Cyprus。

In terms of regulatory coverage, Gate's strategy is closer to “the establishment of independent entities in each of the key jurisdictions and the respective acquisition of licence plates” rather than “crossing multiple countries with one headquarters licence plates”. This approach is more costly, but also more resilient to regulatory risks. In Europe, for example, Gate is a dual insurance policy with both the registration of the VASP of Lithuania (for early EU usage) and the MiCA licence plate of Malta (a pass under the new framework)。

On the other hand, the growth of Gate ' s share in Asian derivatives markets is particularly noteworthy. TokenInsight data show that Gate grew from 4.15 per cent at the beginning of the year to 14.11 per cent at the end of the year in 2025 in the city of OI; the speed at which licence plates were laid was highly synchronized with the rate at which market shares grew。

OKX: REACTIVATE COMPLIANCE FROM SETTLEMENT

OKX's license plate trail, which was completely restarted in 2025. In April 2025, OkX entered into a settlement with the United States Department of Justice to pay a fine of approximately $505 million and formally restarted operations in the United States, with headquarters in San José, California. As of early 2026, OKX held currency converter licences in over 40 states in the United States and was registered as a currency service business in FinCEN。

FOR ASIA, OKX LICENCES ARE DISTRIBUTED AS FOLLOWS:

• Singapore: OKX SG Pte. Ltd. obtained the full main payment agency (MPI) license of the Singapore Gold Regulatory Authority in 2024 and hired former MAS official Gracie Lin to serve as Singapore CEO. The gold content of this license plate is recognized to be high in Asia because of Singapore's MAS verification standards and slow pace of card sales。

• DUBAI: OKX HOLDS VASP PLATES IN VARA, ONE OF THE FIRST INTERNATIONAL EXCHANGES TO SIGN MOUS WITH VARA AND OBTAIN TEMPORARY PLATES。

• Europe: OKCoin Europe Ltd, with Malta as its stronghold, obtained its MiCA licence plate in January 2025, which is available in 30 EEA countries, and was one of the first global exchanges to obtain its full CASP licence。

• Australia: OkX Australia Pty Ltd is registered with ASIC of the Australian Securities and Investment Commission。

HOWEVER, THERE IS ALSO A SIGNIFICANT LICENSING GAP, AND ON THE HONG KONG SIDE, OKX HAS WITHDRAWN ITS VATP APPLICATION, AND ON THE JAPANESE SIDE, AS OF EARLY 2026, OKX WAS STILL ON THE LIST OF OKX RESTRICTED SERVICES. IN OTHER WORDS, THE GOLD-RICH LICENCES IN ASIA ARE CONCENTRATED IN SINGAPORE AND DUBAI, BUT THE MARKETS OF JAPAN AND HONG KONG REMAIN OPEN。

Its license plate narrative may be “to pay the price for re-entering the United States and to exchange it for global institutional trust”。

Why do some plates have no gold

From verifiable regulatory documents and industry practice, encryption plates can be broadly divided into three levels。

First tier: high-intensity gold licence plates

Such licences are characterized by the fact that the issuing agencies are part of the mainstream financial regulatory system, long application processes, high capital and governance requirements, complete retail operations, and the ability to link local banks to the French currency。

Representation cases include:

• The full MPI license plate (OKX SG) for MAS in Singapore. According to Bloomberg, Singapore issued only 13 encryption plates in 2024。

• Type 1 and Type 7 plates for Hong Kong SFC. As of the end of 2024, there were 7 fully licensed virtual asset trading platforms (of which 4 obtained restricted licence plates on 18 December) and 7 others held temporary licence plates。

• IN JAPAN, THE FSA REGISTERS ENCRYPTED MONEY TRADERS. FULL VASP OPERATING LICENSE PLATE FOR DUBAI VRA。

• The UAE's full virtual asset platform operator licence (Bybit) is the first。

• EU MiCA full CASP license plate。

Second floor: medium gold-bearing plates

Such licences are characterized by legitimate operations with limited scope, or regulatory frameworks in the jurisdiction in which they are established, or by the small size of the local financial system。

Representative cases: VASP registrations in EU member States such as Lithuania, Italy, Poland (many exchanges are held, but usually are only ad hoc options for the MiCA transition period), El Salvador BSP and DASP plates, Georgian digital asset plates, Bulgarian VASP plates。

These licences are legal and real in themselves, but are relatively easy to obtain, and therefore holding them alone is less likely to create a competitive threshold。

Third level: low gold content plates

THE CHARACTERISTICS OF SUCH LICENCES ARE THAT THE ISSUING AUTHORITY MAY BE A SMALL FINANCIAL SECTOR, A BUSINESS REGISTER, OR A FREE TRADE AREA REGULATOR. THE LISTING STANDARD MAY REQUIRE ONLY A BASIC KYC/AML PROCESS, AND THE HOLDER MAY NOT BE ABLE TO ENJOY ANY RIGHTS TO ACCESS A FRENCH BANK OR LOCAL RETAIL OPERATIONS. IN TERMS OF CREDIBILITY AND SIGNAL VALUE, SUCH LICENCES ARE CLOSER TO A “CORPORATE REGISTRATION” RATHER THAN A “FINANCIAL LICENCE”。

After grading, we look back at the five exchanges and get a clearer picture:

• Cheon-An has taken six gold-bearing licence plates (including seven for the upcoming Gopax) in Asia, which is its absolute moat。

• OKX has three gold-rich regions in Singapore, Dubai and the European Union, but Japan and Hong Kong are absent。

• Bybit took the full UAE license plate with MiCAR, but was blocked simultaneously in Japan, Hong Kong, Singapore and presented a pattern of “bipolarity”。

• Gate entered Japan through acquisition and obtained MiCA licence plates in Malta, together with the full Dubai VARA operating licence plate, with three footholds in the gold-rich zone。

• Bitget, which is currently the weakest in the gold-rich zone, continues to be dominated by the “widening” of low-middle-middle-bearing gold licence plates。

The next stage of the compliance license competition

From the tracks of these five exchanges, several clear patterns can be summarized。

The era of regulatory arbitrage is over

In the past, exchanges were able to register in Seychelles or the British Virgin Islands and to serve global users through decentrized operating structures, a path that was effectively blocked in 2025. The EU MiCA, the Singapore DTSP system, the Hong Kong VATP framework, and the Japan FSA system are all requiring the exchange to have local entities, licences, compliance and capital readiness。

“Acquisition of licensed entities” is more efficient than “re-application”

This is the logic of the acquisition of Gopax in Korea, the acquisition of Coin Master in Japan, the negotiation of Bybit, the acquisition of Korbit, and the acquisition of Sakura Exchange BitCoin in Japan. For regulators in mature markets (Japan, Republic of Korea), issuance of new licences requires a lengthy review; but allowing existing holders to change shareholder structures is a more viable path。

You're fined, you're certified for compliance

OKX paid $505 million in settlement money and officially entered the United States, and by Bybit Indian subsidiary paid a fine of approximately $10.6 million to register FIU-IND, all of which was counterintuitive: In the encryption industry, the imposition of regulatory sanctions and the completion of settlements are seen as evidence of “cleaning”. Because the problems of the past have been “pricing”, they can be considered as good news of the empty space。

The number of licences will be a key indicator of the value of the enterprise

In the past, the criteria for assessing exchanges were volume of transactions, number of users, number of currencies. In the future, a new item will be added to this list: “The number of gold-bearing plates”. This indicator has begun to influence pricing in the light of recent merger and financing valuations within the industry。

Conclusion: Compliance is not the end, but the new starting line

In the past, industry used to say that “compliance is a cost”. However, data from 2025 to 2026 clearly show that compliance is also revenue。

CoinGecko data show that the total current turnover of the top 10 centralized exchanges was about $18.7 trillion before 2025, an annual increase of 7.6 per cent. In this aggregate growth, the contribution of regulated markets (Europe MiCA, Singapore, Dubai, Japan) is significantly higher than that of unregulated markets, in other words, compliance markets have grown faster than grey markets。

The implications for the five exchanges are that those who obtained full Japanese licence plates between 2026 and 2027, those who passed third-party scrutiny on the VATP list in Hong Kong, those who could be considered by European banks as “qualified counterparties” under the MiCA framework, and those who could pass through MAS in Singapore through an institutional audit, will have the opportunity to jump again in the next round。

FOR USERS AND INVESTORS, UNDERSTANDING THE TRUE GOLD CONTENT OF THE LICENCE, RATHER THAN SIMPLY SEEING THE PROMOTION OF “XX NATIONAL PLATES”, IS THE BASIS FOR JUDGING THE LONG-TERM SUSTAINABILITY OF AN EXCHANGE。

The license plate is not a panacea. In February 2025, while holding multiple licence plates, Bybit was still subjected to 14.60 billion dollars in hacker attacks; in 2024, the Hong Kong JPEX and HOUNAX scandals caused more than $172 million in losses. Licences reduce regulatory risks, but do not eliminate the impact of individual events。

But between licensed, reserve, independently hosted, regularly audited exchanges and those without, the marginal safety gap is magnified in every black swan incident。