How to Set Up a Blockchain / Web3 Company in Saudi Arabia (2026) — The Legal & Licensing Roadmap

Saudi Arabia is one of the most exciting markets in the region for Web3 infrastructure, tokenisation, enterprise blockchain, and fintech-adjacent innovation—but it’s also one of the most misunderstood.

Here’s the truth: Saudi does not offer a simple “crypto licence” you can pick from a menu. In practice, you build your entry strategy in layers:

  1. Company setup foundation (MISA + Commercial Registration)
  2. Correct activity classification (tech vs regulated financial services)
  3. Regulator clearance (SAMA or CMA) if your business touches client funds, payments, exchange, custody, or investment products

Even major advisory firms highlight that there’s no standalone crypto licence and no published rulebook, and approvals are handled case-by-case based on the specific model.

This guide gives you a practical roadmap to set up legally and position your project for approval—without wasting months on the wrong license.

Step 1: Start with the foundation — MISA investment registration

If you are a foreign founder/company, your first layer is typically MISA investment registration (think: “legal entry ticket” before you can properly incorporate and operate).

MISA’s Investor Guide describes the investment registration service as a process aligned with the Investment Law and its regulations, available for approved economic activities (ISIC4), and it outlines required documents such as:

  • foreign company commercial register certified by the Saudi Embassy
  • financial statements authenticated by the Saudi Embassy (last fiscal year)
    …and other activity-specific requirements.

Timeline signal: MISA’s guide indicates an estimated processing time of 10 working days for registering for investment.

Step 2: Choose the correct “lane” — Tech company vs regulated activity

This is the biggest point where founders lose time.

In Saudi, your setup path depends on what you actually do:

Lane A — “Blockchain / Web3 technology” (non-regulated)

This is for projects like:

  • enterprise blockchain development
  • Web3 software studio / product development
  • tokenisation technology provider (without custody, exchange, or handling client money)
  • infrastructure / analytics / compliance tooling

Many founders start here because it allows them to build, hire, lease, and operate while preparing for deeper approvals later.

Advisory guidance commonly notes that capital requirements vary by activity, and that a physical office is mandatory (virtual addresses are not accepted).

Lane B — “Fintech / payments / wallet rails” (SAMA-facing)

If you touch:

  • payment services
  • e-money style flows
  • wallets that interact with fiat/payment rails
  • certain tokenisation/payment-linked models

…you’re entering a lane where the Saudi Central Bank (SAMA) becomes relevant.

A common practical summary is: MISA doesn’t issue crypto approvals; it’s the foundation, and then you seek clearance from the financial regulator depending on your model.

SAMA operates a Regulatory Sandbox framework designed to let innovators test solutions in a controlled environment before market launch.

Lane C — “Exchange / custody / investment products” (CMA-facing)

If you do anything like:

  • exchange platform
  • brokerage style activity
  • investment products linked to tokens
  • custody / client assets

…then the Capital Market Authority (CMA) becomes central.

The CMA’s FinTech Lab is explicitly described as a legislative experimental environment allowing testing of fintech products/services under criteria, time period, and regulatory requirements under CMA supervision.

Important operational detail: the guide also states the applicant must pay the registration fee within 15 business days after being notified of the due amount, otherwise the registration can be considered void.

 

What this means for founders: your documents and attestations must be ready before you start, because delays often come from missing/incorrectly legalized paperwork and Arabic formatting requirements.

Step 3: Understand the “Saudi reality” for crypto approvals (so you don’t overpromise)

A key statement you should build your entire compliance strategy around:

There’s no standalone crypto licence and no published rulebook. Each case is assessed on its own facts.

That single line explains why many founders get stuck: they apply as if Saudi works like “pick a crypto licence, pay a fee, done.”

Instead, Saudi regulators typically want clarity on:

  • who you are (fit & proper)
  • what exactly the product does (flows, risks, custody, settlement)
  • what controls exist (governance, compliance, security, AML/CTF)

And if your model handles client funds, advisory sources often signal that the capital expectations can be materially higher, with SAR 5 million sometimes cited as a typical starting point for firms handling client funds (even when no fixed figure is published).

Practical takeaway: Your fastest route is usually:

  • incorporate correctly (MISA + CR + office)
  • build a regulator-ready pack
  • then approach sandbox/experimental permits depending on the lane

Step 4: Use the sandbox / experimental routes strategically (the “smart” way in)

SAMA Regulatory Sandbox (for SAMA-relevant models)

SAMA’s sandbox is designed so firms can test in a controlled environment for a specified period and, after successful testing, take solutions to market based on regulator guidelines.

SAMA also continues to permit companies into its sandbox; for example, SAMA announced additions in 2025 and noted the total number of fintech companies operating under the sandbox increased (at that time).

CMA FinTech Lab (for securities/investment-relevant models)

CMA’s FinTech Lab is positioned as a supervised experimental environment for innovative models connected to securities activity and market needs.

Fintech Saudi (ecosystem + direction)

Fintech Saudi is a national initiative launched by SAMA in collaboration with CMA to support fintech ecosystem development and guide entrepreneurs.

Founder advantage: If your model is borderline (e.g., tokenisation platform, on-chain settlement tooling, or wallets), a sandbox/experimental path can be your cleanest entry—but only if your documentation is strong.

What you must prepare: “Regulator-ready” pack (this is what wins approvals)

If you want Saudi outcomes, you need a pack that reads like a bank-grade file.

Here’s the checklist I recommend for KSA Web3/Blockchain founders:

Corporate & people

  • Shareholding structure + UBO proof
  • Founder CVs (track record matters)
  • Clean legal declarations (where applicable)
  • Saudi hiring plan / Saudization awareness (practical ops factor)

Product & flows (non-negotiable)

  • One-page business model summary
  • Detailed user journey + transaction flows
  • Custody map: who holds keys, where assets sit, who can move funds
  • Fiat touchpoints: banks, payment processors, settlement partners

Compliance & controls

  • AML/CTF program (risk-based)
  • KYC onboarding approach
  • Sanctions screening approach
  • Incident response plan + cybersecurity controls
  • Data protection posture

Financial & operational substance

  • Saudi office lease plan (physical presence is expected)
  • Capital plan aligned to your lane (especially if client funds involved)
  • Local ops staffing plan and timelines

The fastest way to enter Saudi as “Crypto Girl UAE” (high-demand service angles)

If your goal is to win clients quickly, focus your Saudi services around high-intent business needs:

1) “Saudi Web3 Tech Company Setup” (non-regulated lane)

For founders who want:

  • legal presence
  • correct activity selection
  • office + hiring + CR readiness
  • bank account support
    …and later they can evolve toward deeper approvals.

2) “Sandbox Readiness” (SAMA / CMA)

For serious founders who need:

  • application narrative
  • control frameworks
  • governance + compliance pack
  • risk assessment + testing plan

3) “Tokenisation & enterprise blockchain advisory”

For corporates who want blockchain benefits without touching exchange/custody:

  • supply chain
  • loyalty token mechanics
  • internal settlement rails
  • asset tokenisation feasibility (structure-first)

This mix brings you a strong pipeline because it serves:

  • startups
  • fintech builders
  • corporates exploring blockchain
  • international teams entering KSA
 

 

Frequently Asked Questions (FAQs)

Is there an official “crypto licence” in Saudi Arabia? +

Saudi Arabia does not offer a simple, single “crypto licence” that applies to every business model. Your path depends on what you do (tech development vs. payments/wallets vs. exchange/custody/investment products), and whether you touch client funds or fiat rails.

What is the first step for foreign founders to set up in Saudi Arabia? +

Typically, the starting point is investment registration (often via MISA) before you proceed to commercial registration and operational setup. Exact requirements vary by your activity and entity structure.

When do I need SAMA involvement? +

If your model touches payment services, wallet rails connected to fiat, or regulated fintech activities, SAMA (Saudi Central Bank) may become relevant. Many fintechs explore controlled testing routes (e.g., sandbox-style approaches) depending on the product.

When do I need CMA involvement? +

If your model looks like exchange, custody, brokerage, investment products, or securities-like activity, CMA (Capital Market Authority) may be the key regulator. The correct regulator depends on your exact scope and flows.

Can I set up a Web3 “technology company” first and add approvals later? +

Often yes—if your initial scope stays non-regulated (e.g., software development, enterprise blockchain solutions, analytics, compliance tooling) and you do not handle client funds, custody, or regulated investment activity. If your scope changes later, you should reassess licensing and regulator requirements.

Do I need a physical office in Saudi Arabia? +

In many cases, operational substance matters and a physical office is expected for certain setups and activities. Requirements can vary depending on entity type, activity, and regulator expectations.

What documents should I prepare before starting the process? +
  • Shareholding/UBO structure and IDs
  • Founder/company profile and track record
  • Business model + clear transaction flows (especially if funds move)
  • Compliance pack (AML/KYC, sanctions screening approach, cybersecurity basics)
  • Proof of address / office plan and hiring plan (as applicable)
How long does Saudi Web3 company setup usually take? +

Timelines vary by activity, documentation readiness, and whether regulator clearance is needed. A straightforward tech setup can be faster, while regulated models take longer due to reviews and testing/approval steps.

What’s the biggest mistake founders make when entering Saudi? +

Choosing the wrong “lane” (tech vs. regulated) and describing the business vaguely. Saudi outcomes improve when you show clear flows (who holds funds/keys), strong governance, and a realistic compliance plan.

How can Crypto Girl UAE help? +

I help founders and teams map the correct setup route, prepare regulator-ready documentation, and build an executable timeline (entity setup + operational substance + compliance pack).

Quick start: Share your model in 5 lines (what you do, custody yes/no, fiat touchpoints, target customers, launch timeline).

Note: This content is for general information and does not constitute legal advice. Requirements can change based on your activity and regulator interpretation.

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