Google Play Store Enforces Licensing Rules for Cryptocurrency Wallet Apps

Google has introduced a sweeping policy update that will require cryptocurrency wallet developers to obtain government-issued licenses before publishing apps on the Google Play Store in 15 major jurisdictions, including the United States, United Kingdom, and European Union.

The move applies to both custodial wallets—where companies control users’ private keys—and non-custodial wallets, which simply provide software for users to manage their own keys. This marks a significant shift, as existing laws in many jurisdictions do not impose the same licensing obligations on non-custodial providers.

Policy Details: One Standard for All Wallets

Under the new rules:

• United States – Developers must register with FinCEN as Money Services Businesses and obtain state money transmitter licenses, despite current guidance exempting non-custodial wallets.
• European Union – Developers must secure Crypto Asset Service Provider (CASP) authorization under the Markets in Crypto-Assets (MiCA) regulation.
• United Kingdom – Developers must register with the Financial Conduct Authority (FCA).

By treating both wallet types identically, Google’s policy effectively exceeds the requirements in many regions, creating additional compliance burdens for developers.

Beyond Legal Requirements

Regulatory bodies such as FinCEN and the EU’s MiCA framework typically distinguish between custodial and non-custodial wallets, exempting the latter from certain licensing. For example, FinCEN’s 2019 guidance clearly states that non-custodial wallet providers are not money transmitters.

However, Google’s approach aligns more closely with Financial Action Task Force (FATF) recommendations from 2021, which suggested that decentralized applications could fall under regulated categories if developers maintain some operational control. These FATF guidelines are not legally binding, but Google has chosen to enforce them.

Cost and Compliance Challenges

Meeting these licensing requirements is no small task. Obtaining US state money transmitter licenses can cost hundreds of thousands of dollars, require extensive audits, and demand significant capital reserves. MiCA compliance in the EU also involves robust oversight and operational standards typically aimed at financial institutions.

This could push smaller, independent wallet developers out of the market, consolidating app availability among large companies with the legal and financial resources to navigate complex regulatory landscapes.

Impact of Google’s Market Power

With Android powering around 70% of smartphones globally, the Google Play Store serves as the primary distribution channel for mobile apps. While Android allows sideloading, the process is complex for average users, meaning most will rely on apps available through official channels.

Critics argue this policy amounts to “regulation by commercial enforcement”—a trend where tech platforms implement rules stricter than the law itself, shaping the industry without legislative input.

Broader Implications for Crypto Access

This policy shift arrives during a period of record-breaking cryptocurrency adoption, with Bitcoin reaching $123,000 and stablecoins seeing widespread use for cross-border payments. By imposing strict licensing, Google could unintentionally steer users toward custodial services or web-based wallets, which carry different security and privacy risks.

The move also sets a precedent: if platform-level licensing rules can be enforced on cryptocurrency apps, similar measures could target other decentralized or privacy-focused technologies in the future.