What is wallet as a service (WaaS)?

In short

Wallet as a service (WaaS) is infrastructure, offered through an API or an SDK, that lets a company create and operate crypto wallets for its users or its own treasury without building key management itself. Wallet as a service leaves open who controls the keys, and that design choice decides who is the custodian in law.

Also called
WaaS, Wallet infrastructure, Wallet API
Family
Crypto and trading
Facts checked

How wallet as a service works

The company calls the provider's API to create a wallet, get deposit addresses, read balances and submit transfers. The provider runs the nodes, watches the networks, estimates fees and reports events by webhook.

Keys are generated and protected by the provider's systems, most often with multi-party computation or hardware security modules. A policy engine applies the company's rules before anything is signed:

  • Spending limits per transaction and per day
  • Address allow-lists
  • Approval by several people for large amounts
  • Screening of destination addresses

Who is the custodian in wallet as a service

Three models exist. The provider controls the keys and is the custodian, or the company controls them and the provider supplies only technology, or the end user holds a key share and nobody else can sign alone.

In the EU, MiCA defines custody as safekeeping or controlling, on behalf of clients, crypto-assets or the means of access to them, and the service needs authorisation. Recital 83 says that hardware or software providers of non-custodial wallets should not fall within the regulation's scope.

The model, and which of the two firms holds the authorisation, is therefore the first thing a wallet-as-a-service contract settles.

Wallet as a service, embedded wallet or custodian?

Embedded wallet
The wallet an end user sees inside an app. Wallet as a service is the infrastructure behind it.
Custodian
A regulated firm that holds assets for clients. A wallet-as-a-service provider may be one, or may only supply software.
In-house key management
The same stack built and run by the company: more control, and the full burden of security and upkeep.

Where Wallet as a service shows up in a platform

Modules that do the work

Platforms that need it

Guides that go deeper

Where it is written

The laws and standards this page's facts come from.

General information, not legal advice: what applies to you depends on your services and your market.

Every term

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