Regulatory overview
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- Latest regulatory change
MongoliaMongolia has supervised VASP registration under the FRC, with operating rules and supervisory fees amended in 2026. The regime covers defined services for others while excluding securities and specified monetary instruments. Tokenized investments require prior classification; VASP registration, payment authorisation and enforceability of the represented right are separate questions.
A business launching a virtual asset platform from Mongolia needs to define its functions before seeking FRC registration. Exchange, transfer, custody and offering participation are distinct activities; a token representing securities falls outside the VASP definition and requires a different assessment.
The 2021 law is the starting point, but the project must also consider later operating rules. For the business, that means designing personnel arrangements, controls and contracts from the outset, rather than treating registration as a step that itself validates the investment.
Which activities the VASP law covers
The Law on Virtual Asset Service Providers, adopted on 17 December 2021, establishes registration and supervision for companies providing services within Mongolia or from Mongolia overseas. Parliament identifies commencement as 25 February 2022. Covered activities include exchange, transfers, custody and specified offering services performed for others.
The definition excludes digital representations of official currencies, securities and electronic money authorised by Mongolbank. Resolution 258 of June 2026 also approves operating rules and sets 1 September for provisions 2.16.1 to 2.16.9. An assessment confined to the 2021 statute would miss that regulatory development.
What the FRC supervises and what belongs to Mongolbank
The FRC registers providers and may inspect, restrict, suspend or cancel their activities. Its 2024 annual report documents supervision using operational information and data reporting systems, alongside that year's regulatory consolidation. This demonstrates implementation, rather than providing an up-to-date list of authorised entities in 2026.
Mongolbank retains its own responsibilities, including electronic money; the financial intelligence unit receives information from VASP reporting entities. AML supervision and sectoral registration serve different purposes. Multiple authorities do not allow businesses to choose between permissions or extend banking approval to unrelated virtual asset activities.
Which organisation a registration applicant needs
Articles 7 and 10 require organisation, personnel, controls, lawfully sourced resources and business documentation. Providing services without registration is prohibited. The statutory decision period depends on complete documentation and may be extended; it is neither a guaranteed launch date nor automatic approval through the passage of time.
The supervisory fee schedule revised by Resolution 282 of July 2026 distinguishes exchange and transfers, custody and public-offering services. It is separate from statutory registration stamp duty and required capital. Budgets must identify activities, recurring obligations and compliance expenditure rather than equating one tariff with total establishment cost.
How to connect the offering with purchaser rights
Article 6.2 requires covered public offers and sales to pass through the appropriately registered provider. This does not convert intermediary registration into state approval of the investment. Tokens representing securities require securities-law assessment because their digital representation falls outside the VASP definition.
Documentation must establish whether holders acquire equity, a claim or a contractual right concerning another asset. Platform entries and private-key control do not themselves resolve land title, security interests or enforcement. The statute excludes customer contractual disputes from its specific provider-regulation mechanism.
What the provider must maintain during operations
The VASP statute requires AML controls, security, risk disclosure, accounting and annual audit, and restricts the use of client assets to service provision. Contracts must explain the absence of legal-tender status and deposit-equivalent protection, continuity and return arrangements. These requirements do not guarantee full recovery after losses or insolvency.
The 2026 operating changes must be reflected in applicable procedures and checked against the operative annex. General economic freedom reform, discussed by PwC in September 2026, does not establish that sectoral registration has been removed. Nor does it establish permission to market abroad without complying with destination-country rules.
What to check in the application and current rules
Before launching an offering, establish whether the asset is a security or virtual asset and which participant will perform each service. For VASP activities, prepare the required business plan, technological continuity, internal controls and personnel; customer contracts must explain risks and asset-return arrangements.
Check the file against the current Mongolian text and operating provisions applicable from September 2026. Separate capital, fees and recurring expenditure in the budget, and verify the selected provider’s status: a historical annual report does not establish current authorisation.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- FRC registration is an operational supervised route, not a state guarantee.
- Digital securities require classification outside the VASP perimeter.
- The 2026 operating rules and fees supplement the 2021 statute.
- Supervisory fees, registration stamp duty and own funds are distinct requirements.
Regulatory milestones
VASP statute adopted
Statutory framework for provider registration and supervision.
Statute commences
Date reported by Parliament, with an initial registration transition.
Operating provisions take effect
Date set by Resolution 258 for provisions 2.16.1 to 2.16.9.
Frequently asked questions
No. It establishes the provider’s status within its activities and conditions, without a state asset guarantee or deposit-equivalent protection.
No. The VASP definition excludes digital representations of securities. The right and activity require assessment under the relevant financial legislation.
Article 7.1.4 requires a four-year plan alongside an operating structure and specialised personnel. It should reflect the proposed service and its resources.
Article 8.5 prohibits using customer money or virtual assets for purposes other than providing its services. Controls must make that restriction demonstrable.
Resolution 258 expressly sets 1 September 2026 for provisions 2.16.1 to 2.16.9. That date should not be extended to every other provision without checking its text.
