The Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS Act) has positioned Mauritius as one of the most structured and transparent jurisdictions for digital asset regulation. For crypto founders, fintech companies, and DeFi platforms looking to operate in or from Mauritius, understanding which Virtual Asset Service Provider (VASP) license applies is critical. Two of the most relevant license classes under VAITOS are Class S and Class M. Here’s what they mean, how they differ, and which is right for your business.

What is a VASP License in Mauritius?

Under the VAITOS Act, any person or company conducting certain activities with virtual assets must obtain a license from the Financial Services Commission (FSC). These activities include exchange services, custody, transfer, and operation of platforms dealing in digital assets.

The law outlines five VASP license classes:

• Class R: Fiat-to-crypto exchange
• Class I: Crypto-to-crypto exchange
• Class M: Broker-dealer or custodial wallet services
• Class O: Operating a trading platform
• Class S: Marketplace or other virtual asset-related services

Understanding Class S: Virtual Asset Market Place

Class S is ideal for:

• Platforms that facilitate trades between users (e.g. order matching, decentralized exchanges)
• Non-custodial interfaces that provide routing and liquidity aggregation
• Crypto payment gateways that process transactions without handling fiat

You need Class S if:

• Your platform enables third-party crypto transactions (e.g. marketplace, aggregator)
• You operate an exchange-like interface or dashboard, even if through smart contracts
• Your service routes transactions through liquidity pools but doesn’t custody funds

Minimum capital required: MUR 6.5 million (~USD 140,000)

Understanding Class M: Broker-Dealer / Custodian

Class M is suited for:

• Platforms that hold custody of customer funds (custodial wallets)
• Services that perform crypto lending, pooled yield, or brokerage
• Protocols that manage on-chain assets on behalf of users
  

You need Class M if:

• You offer interest-bearing accounts (e.g. DeFi yield strategies)
• Your smart contracts take control of deposited tokens and execute strategies
• You perform brokerage-like services, even in an automated or decentralized way
  
  

Minimum capital required: MUR 2 million (~USD 43,000)

When Do You Need Both?

Many projects — especially those bridging DeFi infrastructure with user-facing platforms — may require both Class S and Class M licenses.

Example:

A DeFi platform allows users to deposit crypto, routes these funds through smart contracts for yield generation, and uses a dashboard to manage trades and deposits. It doesn’t handle fiat.

• Class S: required for the marketplace/trade facilitation aspect
• Class M: required for custody, yield pooling, and user fund administration
  
  

Combined capital requirement: MUR 8.5 million (~USD 183,000)

Regulatory Expectations

Both licenses come with strict obligations:

• Resident directors and a principal officer
• Local office lease
• Appointment of MLRO, Deputy MLRO, Compliance Officer
• AML/CFT policies, tech audit, business continuity plan
• FSC filings, annual audit, and financial segregation
  
  

Mauritius also enforces the MUR 100,000 KYC threshold, meaning customer due diligence is required for any single or linked transaction reaching that amount (~USD 2,200).

Conclusion: Class S, Class M, or Both?

• If you facilitate trades, run an exchange-like interface, or offer non-custodial services, Class S is required.
• If you hold funds, execute DeFi yield strategies, or act as a custodian, Class M is essential.
• If your platform does both — like many DeFi banks or smart contract-based protocols — you need both licenses.
  
  

Mauritius offers a clear legal path, and the FSC provides structured guidance. With proper planning, you can build a compliant, DeFi-native business with regulatory approval in a credible jurisdiction.