Regulatory overview
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- Fiji
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- Latest regulatory change
FijiFiji has prohibited VASP business since August 2025, including specified promotion, support and services directed at residents from abroad. The prohibition concerns legally defined services and assets, with exclusions for digital representations of instruments governed by financial legislation. Those exclusions require analysis and do not constitute a general tokenization licence.
In Fiji, a business first needs to determine whether its activity falls within the prohibition on virtual asset services. The 2025 amendment reaches specified business activities and related services directed at residents, including where the provider is overseas. A foreign licence or technology structure therefore does not settle market access.
The analysis must distinguish that business from legally excluded financial instruments and software applications outside its perimeter. This guide explains the boundary and the documentation needed to assess a project. There is no general VASP licensing route that opens merely by demonstrating capital or customer controls.
Which activities the 2025 amendment prohibits
The Reserve Bank of Fiji (Budget Amendment) Act 19 of 2025 amended definitions and section 22 of the central bank statute. Since 30 August 2025, conducting, purporting to conduct or holding oneself out as conducting VASP business is prohibited. The provision covers individuals and legal persons located within or outside Fiji.
The RBF notice identifies fiat exchange, virtual asset exchange, transfers, safekeeping, administration and financial services related to issuer offerings for others. The definition concerns specified business activities; it does not establish, without further analysis, that every use of a distributed database is prohibited.
What the RBF and protection authorities do
The Reserve Bank of Fiji communicates the prohibition's scope under its legislation. The National Anti-Money Laundering Council coordinates action against money laundering and other financial crimes. Its support reflects risk and supervisory capacity considerations, but neither replaces the statute nor creates a procedure for commercial exceptions.
The Consumer Council of Fiji has also warned about training programmes promoting virtual asset transactions. This is consumer protection action rather than a new licence category. Describing services as education, community or technical support does not resolve their classification where they facilitate activity within the prohibition.
Why there is no ordinary VASP licence application
Amended section 22 does not create a VASP licence obtainable by meeting minimum capital or AML controls. It covers marketing, advertising, payments, settlement and related technical support or other services to residents. Incorporation elsewhere does not establish that such activities fall outside local scope.
The July 2026 RBF amendment changes profits, accounts and other central bank provisions without altering section 22. It therefore does not establish reopened market access. Innovation proposals or announced future reviews also do not permit operations while the applicable prohibition remains in force.
When financial-instrument exclusions require analysis
The statutory virtual asset definition excludes specified digital representations of fiat, securities and other financial assets within the RBF Act and Companies Act 2015. Actual eligibility for that exclusion requires verification. Calling an instrument a security token or linking it to real estate does not automatically place it outside the prohibition.
For a proposed excluded structure, issuance, intermediation, custody and rights transfer requirements must be checked under the corresponding financial framework. The consulted sources do not establish a specific DLT route turning every token into title to represented property. Legal classification should precede distribution design and project marketing.
How the prohibition affects promotion and supporting services
Breaching section 22 may trigger the statutory criminal penalties, expressly recalled by the RBF. Risk is not confined to executing a purchase: solicitation, advertising, payment integrations and supporting services also require analysis. AML policies do not cure a legally prohibited activity.
The 2026 exchange control amendment introduces sanctioning powers against authorised dealers failing their obligations or acting beyond delegated authority. This provides no alternative route around the VASP framework. The payment or exchange channel and the legality of the service must both comply with applicable requirements.
What to check before developing a project for Fiji
Document what users receive, which entity supplies each service and whether Fiji residents are targeted. Include advertising, payments and technical support alongside exchange or custody. This description allows section 22 to be assessed before distribution contracts are signed or an overseas platform is integrated.
If the project relies on a security or another excluded instrument, provide the documents supporting that classification and its applicable financial regime. A token label does not establish the exclusion. Rights formalities, intermediation and customer restrictions need resolution before testing with real funds; the consulted sources establish no general tokenization-project exemption.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Act 19 of 2025 prohibits defined VASP services; it is more than a warning.
- Foreign establishment does not exclude activities targeting the local market.
- The statutory exclusion for certain financial instruments does not authorise all tokenization.
- The 2026 central bank amendment does not amend the section 22 prohibition.
Regulatory milestones
Act 19 of 2025 assented to
Definitions and the section 22 prohibition are amended.
RBF notice
The authority explains activities, scope and consequences.
Frequently asked questions
Section 22 prohibits the defined VASP business rather than creating a licensing procedure based on capital or AML controls. Legally excluded instruments require separate analysis.
Yes. The provision covers persons within or outside Fiji and specified related activities directed at residents, including promotion and technical support. Scope must be checked for the particular activity.
The RBF notice expressly includes advertising, marketing and holding oneself out as conducting VASP business. Analysis therefore does not start only when a trade occurs. Check what is advertised, its intended audience and its connection to the prohibited service.
Act 19 of 2025 excludes specified representations of securities and financial assets covered by the identified legislation. Property backing does not establish that classification. The right, issuer and applicable regime must be identified; a token may represent a contractual claim without transferring direct ownership.
The prohibition communicated by the RBF is not a licence conditional on controls. Customer identification or prevention policies do not authorise the VASP business within scope. First determine whether the activity is prohibited or an applicable statutory exclusion covers the particular instrument.
