Self-custodial wallet / non-custodial software in Andorra
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is permitted in Andorra with no licensing burden.
Verdict Details
- Permitted
- yes
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
Key Restrictions
- The publisher must not hold, control, or have access to user private keys or funds — this is definitional to the self-custodial model.
Key Risks
- Regulatory ambiguity: The definition of 'custody and/or administration of virtual assets or instruments enabling control over virtual assets' (ad.aml.custody-andor-administration-of-virtual) could theoretically be interpreted broadly by the AFA to encompass software that enables key generation, though this would be an aggressive reading.
- If the software publisher also offers any integrated services (e.g., fiat on-ramp, swap aggregator, staking delegation) those could trigger VASP licensing obligations.
- Future regulatory developments could bring non-custodial software under AML obligations even if currently exempt.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Exchange between digital assets and fiat currencies: This covers cryptocurrency exchanges that allow users to buy and sell crypto with traditional money (EUR, USD, etc.).
Exchange between one or more digital assets: This covers crypto-to-crypto exchanges, but modern regulatory frameworks now also include fiat-to-crypto transactions, crypto ETF/ETP creation and redemption models, and broker-dealer or clearing functions as part of digital asset exchange definitions.
Custody and administration of digital assets on behalf of third parties: This covers services where an entity holds or controls private keys for virtual assets on behalf of clients.
Custody and/or administration of virtual assets or instruments enabling control over virtual assets.
Requirement: Any entity providing custody services for virtual assets on behalf of third parties is considered a "Virtual Asset Service Provider" (VASP) under Ley 28/2022 and must be authorized by the Autoritat Financera Andorrana (AFA).
Definition of Custody: Article 3, point 16 of Ley 28/2022 defines "custodia de activos virtuales" (custody of virtual assets) as the safekeeping or administration of virtual assets or instruments enabling control over them on behalf of third parties.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Yes — a publisher of self-custodial software (where the publisher never holds or controls private keys) is not considered a VASP in Andorra because it does not engage in any of the licensed activities (exchange, custody, transfer, etc.) and AML obligations do not attach where no custody or control over assets exists.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?