Since 10 Jan 2020, the Financial Conduct Authority (FCA) has been the anti-money laundering supervisor of UK cryptoasset businesses. Cryptoasset businesses must register with the FCA under the Money Laundering Regulations (MLRs) before starting any in-scope services in the course of business they carry on in the UK. From 25 Oct 2027, anyone carrying on the new regulated cryptoasset activities by way of business in the UK needs FCA authorisation under the Financial Services and Markets Act 2000 (FSMA), with permission to carry on those activities, unless there is a relevant exemption or they can use the savings or transitional run off provisions. In this guide, an FCA crypto licence means that authorisation. Firms can apply for authorisation from 7am on 30 Sep 2026, and the application period closes on 28 Feb 2027.
MLR registration continues after the new regime starts. The FCA says the MLR and FSMA regimes will continue to operate concurrently, and cryptoasset exchange providers and custodian wallet providers that are not authorised cryptoasset firms (or specified investment cryptoasset firms) are required to be registered under the MLRs. The figures box above shows Sherpa's figures for the MLR registration regime, not for the new authorisation regime.
The regime in brief
Parliament passed the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (the Cryptoassets Regulations) on 4 Feb 2026. From 25 Oct 2027, they bring new regulated activities for cryptoassets into the FCA's perimeter.
Since January 2020, cryptoasset exchange providers and custodian wallet providers operating in the UK have had to register with the FCA and comply with the MLRs. Firms carrying out the newly regulated activities by way of business in the UK will instead need FSMA authorisation, unless an exemption applies. The FCA says these firms will no longer be required to register separately under the MLRs, but must still comply with the MLRs where they act as a cryptoasset exchange provider or custodian wallet provider.
The FCA's information on registering under the MLRs before the new regime starts covers only firms that will benefit from one of the exemptions from registration under Regulation 54(1A)(b) of the MLRs. The FCA says firms that will not benefit from one will still need to register once the FSMA regime has begun, and the MLR gateway will continue to operate as normal for them. For the firms its information covers, the FCA says they may apply for registration at any time before the new regime begins, but should only do so if they are confident that they can be registered early enough for it to be worthwhile before the new regime starts. The FCA said that once the FSMA gateway opened, it would encourage these firms to focus on securing authorisation under FSMA rather than applying for registration, and the gateway opened on 30 Sep 2026. The FCA says a firm in this group that still wants to apply for registration after 30 Sep 2026 should contact the FCA's pre-application support service (PASS) to explain its plans and why it needs registration. The FCA's deadline for deciding a registration application is 3 months from receiving the application form, or from receiving any further information it requires, so the FCA says these firms should not apply for registration after 31 Jul 2027, because it is unlikely to decide their application before the new regime starts. Being registered under the MLRs does not guarantee authorisation under FSMA.
The UK's financial promotions regime applies to all firms marketing cryptoassets to UK consumers, regardless of where the firm is based.
The FCA published its final rules and guidance on 30 Jun 2026 (PS26/9 to PS26/13) and final perimeter guidance on 16 Sep 2026 (PS26/18), which Anvesan covered in a News story. See also the United Kingdom regime page and the regimes index.
Which activities need authorisation
PS26/18 sets out the new regulated cryptoasset activities as follows:
- issuing qualifying stablecoins in the UK;
- safeguarding, and arranging safeguarding of, qualifying cryptoassets and relevant specified investment cryptoassets;
- operating a qualifying cryptoasset trading platform;
- dealing in qualifying cryptoassets as principal;
- dealing in qualifying cryptoassets as agent;
- arranging deals in qualifying cryptoassets;
- arranging qualifying cryptoasset staking.
Cryptoasset lending and borrowing are not standalone regulated cryptoasset activities: the FCA says whether a person needs authorisation for such an arrangement depends on the particular activities it carries on, including dealing, arranging and/or safeguarding. The FCA also says advising on and managing investments are not new regulated cryptoasset activities, but those existing activities may still be relevant for specified investments, including specified investment cryptoassets.
The FCA's guidance says the business test is narrower than the one FSMA uses for regulated activities generally: unless a person carries on the business of engaging in the activity, the person is not seen as carrying it on by way of business. It says the Cryptoassets Regulations expand what counts as 'in the UK' for certain activities, subject to certain exclusions: activities involving UK consumers may be treated as carried on in the UK even where the person carrying on the activity is established overseas.
PS26/18 covers the Cryptoassets Regulations as passed on 4 Feb 2026. It does not yet include an amending statutory instrument that the Government has laid before Parliament. The FCA says that instrument will affect certain business models and the permissions they may need, but that the changes will not affect most crypto firms. The FCA plans to consult on updated guidance in October 2026 and aims to publish final amended guidance in early 2027.
Who is affected
The FCA says existing registrations and permissions will not convert automatically. Firms authorised under FSMA, registered under the MLRs, or authorised or registered under the Payment Services Regulations or Electronic Money Regulations will need to be appropriately authorised if they carry on a regulated cryptoasset activity by way of business in the UK that no available exclusion or exemption covers.
- Firms already authorised under FSMA that want to carry on a new regulated cryptoasset activity will need to vary their existing permissions, through a variation of permission.
- Firms relying on a section 21 approver to approve their financial promotions will need to be authorised if they are within scope of a regulated cryptoasset activity.
- Overseas firms serving UK consumers cannot rely on the overseas persons exclusion for the new regulated cryptoasset activities, because the Cryptoassets Regulations do not apply it to those activities. In its guidance FG26/7, the FCA expects firms seeking authorisation for these activities to have a presence in the UK, and its baseline expectation is that they carry out the activities from a UK legal entity. It allows some specific exceptions, where it sees a case for an overseas firm serving UK customers through a UK branch to be authorised as a qualifying cryptoasset trading platform operator. In those cases the FCA expects the home regulator to have comparable levels of regulatory protection and regulatory requirements in place, as determined by the FCA.
Key dates
| Date | What happens |
|---|---|
| 30 Sep 2026, 7am | The gateway opens and the application period starts. |
| 28 Feb 2027 | The application period closes. |
| 25 Oct 2027 | The new regime starts. |
The FCA expects to determine applications made within the application period before the regime starts. If it has not determined a firm's application by then, a saving provision in the Cryptoassets Regulations lets that firm continue to provide cryptoasset services until the application has been finally determined, subject to meeting the relevant conditions. If the FCA has refused the application but the refusal is still open to review, the FCA may, in certain circumstances, direct the firm to enter the transitional provision instead. Firms that apply after the period closes cannot rely on the savings provisions.
A firm that applies, for authorisation or a variation of permission, after the period closes but before the regime starts, and does not have the required permissions when the regime starts, enters the transitional provision by operation of law while its application is determined. That provision allows the new activities only as far as needed to perform contracts made before the firm entered it, and allows a wind-down of remaining UK business over a maximum two-year period. A firm that does not apply for authorisation or a variation of permission before the regime starts must run off its UK cryptoasset business before the regime starts, and cannot use the saving or transitional provisions.
Requirements at headline level
The figures box at the top of this guide shows Sherpa's signed-off figures for a UK crypto exchange, as of 19 Sep 2026: a decision time of 3 months after the FCA has what it needs, and an application fee of GBP 11,260. Both belong to the current registration regime: registration as a cryptoasset business with the FCA, which the FCA runs under the MLRs. They are not the fee or the timeline for authorisation under the new regime, for which this guide has no signed-off figures. To see what Sherpa shows for a UK crypto exchange, open Sherpa's Pathfinder.
To be authorised, a firm must show that it satisfies, and will continue to satisfy, the minimum standards in FSMA, known as the Threshold Conditions. Once authorised, it will need to follow the rules in the FCA Handbook, which with the FCA's guidance form what the FCA calls its core cryptoasset regime. The FCA says it is applying key Handbook obligations, including the Consumer Duty, the Senior Managers and Certification Regime (SM&CR), operational resilience and financial crime.
How to apply
From 7am on 30 Sep 2026, firms can apply through the FCA's online system: for authorisation, or, if already authorised under FSMA, for a variation of permission. The FCA has prepared an information document on the application form, which it says it provides on a best endeavours basis, and applicants must complete an updated financial data template.
Before applying, a firm can request an optional, free pre-application meeting through PASS. The request must describe the proposed business model, products and services and customer types, and the FCA says it should include an analysis of the regulated activities the firm intends to apply for. The FCA rejects requests without meaningful supporting information. The FCA does not give advice, and a meeting does not guarantee a successful application.
The FCA encourages firms to apply as soon as possible within the application period. It will not expedite its assessment to make up for a late submission, meaning one made after the application period has closed. It can reject applications that lack the minimum information it asks for, and treats a firm that does not then submit a valid application as not having applied. It says dual-regulated firms should also contact the Prudential Regulation Authority (PRA).
How to check a firm on the FCA register
The FCA says that in the UK, nearly all financial service activities must be authorised or registered by it. The FCA's Financial Services Register lists all firms and individuals involved with regulated activities that the FCA has currently or previously approved. When the FCA approves a cryptoasset business's application for registration under the MLRs, it writes to confirm the registration, tells the firm its Firm Reference Number (FRN) and adds the firm to the register. The FCA says the register also holds information that the FCA's consumer Firm Checker leaves out, including published restrictions relating to crypto activities.
A name on the register is not proof of registration on its own. The register also lists firms the FCA has been told are providing regulated products or services without the correct authorisation, or deliberately running scams. It includes the details unauthorised firms give out, and whether they are falsely claiming to be from a genuine, authorised firm (a clone firm).
The register also has the FCA's Unregistered Cryptoasset Businesses page. In a notice to all FCA-regulated firms with exposure to cryptoassets, the FCA says authorised and registered firms should be reviewing whether the cryptoasset businesses they interact with are listed on that page, and it expects firms doing business with cryptoasset firms to check against the list.
Registration is not an endorsement. The FCA says registration under the MLRs is a legal requirement to carry on business, not a recommendation or endorsement of the business, and that registered cryptoasset businesses should avoid language suggesting that FCA registration is an endorsement or recommendation. It also says being registered with the FCA as a cryptoasset business does not mean customers benefit from the protections of the Financial Ombudsman Service or the Financial Services Compensation Scheme (FSCS).
Registration under the MLRs is not authorisation under FSMA, and the FCA says existing registrations will not convert automatically. The FCA explains which businesses must register under the MLRs on its page on who needs to register.