If you're a crypto founder planning your go-to-market budget, you need to understand exactly what you're signing up for. This guide breaks down BitLicense costs, broader crypto licensing expenses, and how these stack with money transmitter licenses (MTLs) so you can model your regulatory spend accurately.
What Is a BitLicense and When Do You Need One?
The New York Department of Financial Services (NYDFS) created the BitLicense specifically for crypto companies operating in New York. If your business offers custody, virtual currency transmission, exchange services, or controlling, administering, or issuing a virtual currency (including many stablecoin issuers) to New York customers, you'll need one. Non‑custodial software on its own does not trigger BitLicense requirements.
What makes BitLicense different from a standard MTL? Two things: the approval process is notoriously slow, with many applicants reporting 18–24+ months from initial submission to approval, depending on business model complexity and completeness of the application. BitLicense compliance standards are among the most rigorous in the country. While some license applicants attempt to keep these costs internal, it is prudent to set aside additional funds for legal and advisory fees in the event you need to negotiate with regulators or want expert feedback on your application and proposed compliance program. These factors drive costs significantly higher than typical state licensing.
You can also expect the costs of maintaining the license to grow each year. BitLicense holders fall under Section 206 of the New York State Financial Services Law. This means that regulated persons and entities engaging in “virtual currency business activity” within the state foot the bill for all operating expenses of the Virtual Currency Unit. The NYDFS releases detailed assessment calculation charts quarterly so you can develop an understanding of future costs before you receive your BitLicense.
Activities that trigger BitLicense requirements:
- Crypto custody or wallet services for NY customers
- Fiat-to-crypto on/off-ramps
- Virtual currency exchanges
- Stablecoin issuance or redemption
The critical distinction: BitLicense doesn't replace your MTL obligations—it's in addition to them. Operating in New York means you need both.
One-Time BitLicense Application Costs
Getting BitLicense-ready requires substantial investment across regulatory fees, legal counsel, and internal infrastructure. Here's what crypto companies typically spend:
Total Year-One Costs (All 50 States + DC)
| Cost Category | Typical Range | What's Included |
| NYDFS Application Fees | $5,000 | Paid directly to NYDFS |
| Credit Report Fees | $15 | Per control person |
| Legal/Advisory Fees | $50,000+ | Application preparation assistance, regulator negotiations, compliance program consultation and/or review |
| Surety Bond or Trust Account | $2,500-50,000 | NYDFS requires license holders to maintain a $500,000 surety bond or higher based off of risk profile and anticipated activity |
| Capital Requirements | Varies based on business model and NYDFS assessment | |
| Internal Compliance Enhancements | $250K–$1M+ | Additional compliance personnel, policy creation and internal resource development, expanded AML monitoring tools |
| Total Upfront | $350K–$1.5M+ | Varies significantly by company size and complexity |
These numbers can be daunting, but there are ways to reduce costs. Brico's crypto licensing software cuts legal hours by automating BitLicense documentation alongside your MTL filings.
Ongoing BitLicense and Crypto License Maintenance Costs
Here's what catches many founders off guard: year-two-and-beyond expenses often exceed what you spent on the initial application. Getting licensed is the start, but maintaining a BitLicense is an ongoing financial and operational commitment.
What NYDFS Requires of Licensed Firms
Once you're licensed, NYDFS expects you to maintain rigorous standards across multiple areas:
- Regular examinations by NYDFS (requiring significant preparation time and resources)
- Capital and liquidity standards that must be met continuously
- Cybersecurity and consumer protection programs that meet NYDFS's stringent requirements
- Quarterly and annual reporting to the department
- Quarterly assessments (paid five times per year), calculated based on your custody holdings and transaction volume
For most startups, these assessments alone translate to $15,000 to $80,000+ per year in direct regulatory fees, with the exact amount determined under DFS’s custody‑ and transaction‑based tiers. That does not include costs for audits, legal reviews, or compliance staffing.
The Full Cost Picture
Total Year-One Costs (All 50 States + DC)
| Cost Type | Annual Range | What Drives It |
| NYDFS Renewal/Exam Fees/Annual Assessment Charges | $15K–$80K+ | Scales with your transmission volume |
| External Legal/Compliance | $50K–$300K | Interim program and policy consultations, exam preparation assistance, Advance Change Notices, annual independent audits |
| Internal Compliance Operations and Ongoing Enhancements | $300K–$1M+ | Additional compliance personnel, ongoing policy maintenance and internal resource development, AML solution enhancements and/or subscription fees |
| Total Annual | $400K–$1.5M+ | Scales with your NY revenue volume |
For many crypto programs, BitLicense can roughly double or triple the New York‑specific share of ongoing compliance spend relative to a typical state‑MTL footprint, driven by NYDFS examination intensity and local staffing needs.
How BitLicense Costs Compare to MTL Costs
For crypto companies serving New York customers, BitLicense sits on top of your nationwide MTL costs. Here's how the numbers break down across different licensing approaches:
Total Year-One Costs (All 50 States + DC)
| Scenario | Licenses Needed | Upfront Costs | Annual Costs |
| Nationwide MTLs only (excluding NY) | 30–50 state MTLs | $250K–$350K | $300K–$800K |
| MTLs + BitLicense (full U.S. including NY) | 30–50 MTLs + BitLicense | $1M–$3M+ | $1M–$2.5M+ |
| BaaS/Sponsor Bank (no licenses) | Bank partnership | $100K–$500K | Revenue share (3–10%) |
Revenue share (3–10%)
The jump from "nationwide without NY" to "full U.S. coverage" is significant—you're essentially doubling your regulatory spend to access a single state. Whether that math works depends on how much of your customer base is in New York.
For the complete breakdown on MTL expenses, see our guide: How much do MTLs cost? Complete Guide, 2025.
Example Crypto Licensing Cost Scenarios
Every crypto business has a different licensing profile. Here's what three common scenarios typically look like:
Crypto Exchange (U.S. + NY)
A full-scale exchange serving customers nationwide including New York faces the highest licensing burden:
- MTLs (40 states): $1.5M upfront + $600K/year
- BitLicense: $800K upfront + $400K/year
- Total: $2.3M upfront + $1M/year
Custodial Wallet (U.S. excluding NY)
Some companies make a strategic decision to exclude New York customers entirely, avoiding BitLicense costs:
- MTLs (40 states, no BitLicense): $1.2M upfront + $500K/year
- Total: $1.2M upfront + $500K/year
Stablecoin Platform (NY-focused)
Stablecoin issuers often can't avoid New York given its financial industry concentration, but may not need full nationwide coverage:
- BitLicense + select MTLs: $1M+ upfront + $800K/year
- Note: NYDFS scrutiny is significantly higher for stablecoin operations
How Brico Reduces BitLicense and Crypto Licensing Costs
Brico's crypto licensing software for MTLs and BitLicense cuts costs 50–70% compared to traditional law firm approaches. Here's how:
- Automates 200+ forms across MTLs and BitLicense (both NMLS and NYDFS portals)
- Smart data mapping reuses your core information across all filings
- Built-in checklists prevent costly Requests for Information from regulators
- Expert-in-the-loop support helps you avoid application rejections
Ready to apply? Demo Brico to see how compliance can give you a competitive edge.
Disclaimer: This article is for informational purposes only and does not constitute legal, financial, or regulatory advice. Brico is not a law firm and does not provide legal counsel. Licensing requirements vary by state and depend on your specific business model and circumstances. You should consult with qualified legal counsel before making any licensing decisions or taking action based on this content.
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