The claim is everywhere, and two thirds of it is wrong. Gibraltar was not the first country in the world to regulate crypto. It is not a country, and it was not first. What it did do, on 1 January 2018, is narrower than the headline and more interesting than it. Gibraltar wrote the first purpose built licensing regime for firms that use distributed ledger technology to hold or move value belonging to somebody else. That claim is defensible. The bigger one is not, and the government's own agencies have quietly stopped making it. Below is what the law actually says, what a licence costs, how long it takes, and why the process puts founders physically in Gibraltar for weeks at a time. Every figure links to the document it came from. Where we could not verify something, we say so instead of guessing. Gibraltar is a British Overseas Territory of 37,936 people at the 2022 census. It has its own parliament, its own courts and its own financial services legislation, and it is a member state of nothing. Calling it a country is the shorthand that makes a superlative sound bigger than it is. We have written at length on [what Gibraltar's status actually is](/blog/is-gibraltar-a-country-status-explained). The right word is jurisdiction. It matters here, because the jurisdictions Gibraltar was racing on timing were a US state, a Crown Dependency and a G7 economy. New York was the earliest of the three. The state's Department of Financial Services adopted its virtual currency regulation, 23 NYCRR Part 200, the rule everyone calls the BitLicence, and it took effect on 24 June 2015. [The DFS still licenses virtual currency businesses under it](https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses), across five categories of activity from custody to exchange to issuance. It is a state regime rather than a national one, and that is the only thing standing between New York and the outright title. The Isle of Man moved in 2015 as well, pulling convertible virtual currency businesses into its anti money laundering regime under the Designated Businesses (Registration and Oversight) Act 2015. [The Isle of Man Financial Services Authority's own sector guidance](https://www.iomfsa.im/media/2688/sector-guidance-virtual-assets.pdf) is careful about what that means: registration and oversight for money laundering purposes, not a financial services licence. The distinction is genuine, and it is what leaves room for Gibraltar's claim. Japan is the awkward one. The amended Payment Services Act came into force in April 2017, nine months ahead of Gibraltar, and it was never only an AML measure. [The Japanese Financial Services Agency's own account of the reform](https://www.fsa.go.jp/inter/etc/20221207/01.pdf) lists minimum capital requirements, mandatory disclosure to customers, segregation of customer assets and secure systems management alongside the registration system for crypto asset exchange service providers. That is prudential regulation, and it predates Gibraltar. |Jurisdiction|In force|What it actually was| |New York State|24 June 2015|A state licensing regime for virtual currency business| |Isle of Man|2015|Registration and AML oversight of virtual currency firms, not a licence| |Japan|April 2017|Registration of crypto asset exchanges, with capital and asset segregation rules| |Gibraltar|1 January 2018|A licensing framework written for DLT firms as a class, on nine core principles| Read across that table and Gibraltar's position is clear enough. Fourth by date. First by design. The regulations were published on 12 October 2017 and came into force on 1 January 2018. They did not regulate an asset. They regulated a technology used in one particular way, which is why the framework has outlasted eight years of the market underneath it changing shape three or four times. The instrument in force now is the [Financial Services (Distributed Ledger Technology Providers) Regulations 2020](https://www.gibraltarlaws.gov.gi/legislations/financial-services-dlt-providers-and-vaa-providers-regulations-2020-4774), LN.2020/012, which commenced on 15 January 2020 and has been amended four times since. The official language has drifted, and the drift is the tell. In September 2020 the government wrote that Gibraltar became the very first jurisdiction globally to introduce legislation around distributed ledger technology, in [a press release about refreshing the framework](https://www.gibraltar.gov.gi/press-releases/gibraltar-regulator-refreshes-jurisdictions-distributed-ledger-technology-regulation-6312020-6206). Gibraltar Finance now calls the regulations [one of the first pieces of legislation worldwide that specifically caters to DLT](https://www.gibraltarfinance.gi/technology/distributed-ledger-technology). One of the first. Somebody in the Finance Centre checked. > Fourth to regulate. First to write a rulebook for the technology instead of the coin. Under Schedule 2, Part 16, paragraph 139 of the Financial Services Act 2019, t