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Jurisdiction Selection Framework for Web3 Companies in 2026
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Jurisdiction selection framework for Web3 in 2026: MiCA's grace period ended 1 July 2026 and US stablecoin rules lag. Evaluate six weighted criteria first.
Frequently Asked Questions
- No single hub wins for every business, because the answer depends on the weights. On our six-criterion matrix for a trading, custody or tokenisation business, scored in September 2026, the EU scores 84 of 100, Singapore 76, Dubai 68, Hong Kong 66 and the US 59. A business that will serve one domestic market should grade or weight passport reach lower, which narrows the EU's lead.
- Generally no. The MiCA transitional period ended across the EU on 1 July 2026, and ESMA says any entity providing crypto-asset services to EU clients without a MiCA licence is in breach of EU law. Firms established outside the EU may not serve or solicit EU clients, outside a narrow reverse solicitation exception for services requested at the client's own exclusive initiative (ESMA, April and June 2026).
- It is law but not yet effective. The Act was enacted on 18 July 2025 and takes effect on the earlier of 18 months after enactment or 120 days after the primary regulators issue any final rules (Cornell LII, 2025). No primary federal regulator had issued final rules by late September 2026, so the 18-month limb governs and the Act takes effect on 18 January 2027; Treasury's own issuance rules were still a proposal, with comments due by 19 October 2026 (Federal Register, August 2026).
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