Google Play Update: Licensing Requirements for Crypto Apps

 
Over the past several months, Google has updated and begun actively enforcing its Cryptocurrency Exchanges and Software Wallets policy within the Google Play store. This update links app distribution directly to regulatory status in the jurisdictions where an application is made available. For many crypto platforms, the practical impact is immediate.

What Has Changed

Google Play now requires verified, government-issued licensing or registration documentation for certain categories of crypto-enabled applications.

The change is intended to align app distribution with evolving regulatory frameworks, including:

• MiCA in the European Union
• FinCEN MSB registration and applicable state-level requirements in the United States
• FINTRAC registration in Canada
• FCA registration in the United Kingdom
• VARA licensing in the United Arab Emirates
• FSCA registration in South Africa
• Additional frameworks in jurisdictions such as South Korea (VASP), Japan (FSA), Brazil, and others

As part of this enforcement shift, Google has implemented what is effectively a hard block on app updates for developers who have not submitted valid proof of licensure in regulated regions where their app is distributed.

Who Is Affected

Two primary categories of apps fall under the updated policy:

1. Cryptocurrency Exchanges: Platforms that allow users to purchase, sell, or trade digital assets.
2. Software Wallets: Applications that enable users to store, send, or manage cryptocurrency.

It is important to distinguish between custodial and non-custodial models. A standard non-custodial or decentralized wallet that does not hold user funds in custody may remain available without obtaining a license, provided it does not perform regulated custodial or exchange activities.

However, any application that facilitates trading, custody, conversion, or asset management in a regulated jurisdiction should review whether licensing obligations apply. Enforcement is based on where the application is accessible, not where the company is incorporated.

Actions Now Required

To remain compliant, app owners are required to complete the following:

1. Financial Features Declaration
Within the Google Play Console under Policy & Programs → App Content, the application must be formally declared as a cryptocurrency exchange and/or software wallet.

2. Jurisdiction-Specific Licensing Documentation
For certain regulated regions, Google will automatically request official documentation confirming registration or licensure. This documentation must correspond to the regulatory requirements applicable in that jurisdiction.

3. Removal of Unlicensed Regions
If documentation cannot be provided for a particular country, that region must be removed from the app’s distribution settings to avoid enforcement action.

4. Ongoing Compliance Responsibility
Google’s policy does not replace local legal obligations. Developers remain responsible for complying with applicable regulatory requirements in all jurisdictions where their application is accessible.

Failure to complete these steps, or submission of insufficient documentation, may result in:

• Regional delisting
• Blocked updates
• Suspension or termination of the developer account

Practical Considerations for Operators

For multi-jurisdiction exchanges, brokers, fintech platforms, merchant processors, and asset management tools, this development requires a structured review of:

1. Current distribution footprint within Google Play
2. Existing licensing and registration coverage
3. Gaps between distribution and authorization

Where licensing status is unclear or incomplete, corrective action may be required before updates can proceed without disruption.

How Shift Markets Can Assist

Our legal and regulatory team works with crypto exchanges, brokers, and fintech platforms operating across multiple jurisdictions.

We provide:

• Jurisdiction-level licensing assessments based on distribution footprint
• Guidance on required registrations and authorizations
• Licensing procurement support through established regulatory partners
• Assistance coordinating documentation for Google Play Console submissions

Teams that have not recently reviewed their licensing posture in relation to their distribution strategy should consider doing so promptly.

If you would like to assess whether your application is affected, our team is available to discuss your specific situation.

Drew Barron
VP of Legal