According to New York State's Department of Financial Services, anyone engaging in any of the following activities will be required to obtain a BitLicense:
- Virtual currency transmission
- Storing, holding, or maintaining custody or control of virtual currency on behalf of others
- Buying and selling virtual currency as a customer business
- Performing exchange services as a customer business
- Controlling, administering, or issuing a virtual currency.
As of February 2020, consumers are not required to have a BitLicense to transact in virtual currencies. Merchants also do not require BitLicense to accept virtual currencies as payment.