Google Confirms Non-Custodial Wallets Will Be Exempt from New Licensing Requirements

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Google has reversed its decision to require licenses for all cryptocurrency wallet applications, confirming that non-custodial wallets will be exempt from the new licensing requirement.

Controversial Initial Policy

The Google Play Store initially announced a policy requiring cryptocurrency wallet app developers in 15 jurisdictions, including the U.S., U.K., and EU, to obtain government licenses for both custodial and non-custodial wallets.

Initial Requirements:

In the U.S.: Developers must register as a Money Services Business (MSB) with FinCEN or hold a federal/state banking license.
In the EU: Must be recognized as a Crypto-Asset Service Provider (CASP) under MiCA regulations.
Implementation Timeline: Canada from July 2025, Germany requires BaFin licensing within the year, and the entire EU applies MiCA before June 2026.

The updated initial policy raised concerns about self-managed wallets before Google confirmed their exemption. In an official announcement, Google stated: “Non-custodial wallets are not within the scope of Google Play’s Cryptocurrency Exchange and Software Wallet Policy. We are updating the Help Center to clarify this.”

Current Policy Impact

The current policy requires cryptocurrency wallet app developers in the 15 jurisdictions to have licenses, but it does not apply to non-custodial wallets.

Affected Parties:

Custodial wallets (holding users’ assets)
Cryptocurrency exchanges
Crypto financial services with custodial features

Exemptions:

Non-custodial/self-custodial wallets (users manage their own private keys)
Apps that only provide encryption key management tools

Market Impact Analysis

Independent custodial wallet developers face the highest risk of losing distribution rights in key markets due to the costs and complexity of obtaining licenses. Regulated large companies may maintain their presence, potentially increasing centralization in the crypto wallet market.

Google’s move comes amid widespread adoption of digital assets, with Bitcoin reaching a record $123,000 in August 2025. The July policy requires software wallet developers to comply with local financial regulations to ensure a safe and compliant ecosystem for users.

Implications for Vietnamese Users

Although Vietnam is not directly affected as one of the 15 jurisdictions, Vietnamese users may still face restrictions when accessing some international wallet applications that do not comply with the new requirements.

Google’s clarification regarding non-custodial wallets is positively viewed by the crypto community, helping to protect decentralization and users’ rights to manage their assets—core principles of blockchain and cryptocurrency.

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