The Financial Conduct Authority (FCA) has released its final guidance on which cryptoasset activities will fall within the perimeter of the UK’s new regulatory regime.
The guidance marks a decisive shift for the sector: from 25 October 2027, any firm carrying out regulated cryptoasset activities in the UK will need FCA authorisation, unless an exemption or transitional provision applies, as discussed by Cardamon CEO Areg Nzsdejan in a recent LinkedIn post.
The scope of the regime is broad. Activities set to require authorisation include safeguarding cryptoassets, operating a cryptoasset trading platform, dealing in cryptoassets as either principal or agent, arranging cryptoasset transactions, and certain staking activities. Together, these cover much of the commercial infrastructure the UK crypto market currently relies on.
The most significant element of the guidance may be the FCA’s emphasis on substance over branding. The regulator has made clear that it will judge firms by the activities they actually perform, not by how they describe themselves. A business marketing itself as a “wallet”, “exchange”, “platform” or “broker” will not be able to rely on that label to determine its regulatory status. What matters is the underlying activity. For firms that have structured their products or messaging around particular terminology, this removes any room for ambiguity and places the onus on them to understand exactly what they are doing in regulatory terms.
The timeline is now fixed. The application window opens on 30 September 2026. Firms wishing to benefit from the transitional arrangements must submit their applications by 28 February 2027, when that window closes. The full regime then takes effect on 25 October 2027. With the gateway opening in days, firms have a limited period to prepare applications that meet the regulator’s expectations.
Crucially, existing FCA registrations and permissions will not automatically carry over into the new regime. Firms already registered with the regulator, including those operating under current anti-money laundering registrations, will need to assess whether they require fresh authorisation or a variation of their existing permissions. This means even established players cannot assume they are already compliant.
For the wider market, the guidance brings long-awaited clarity but also real pressure. Firms that misjudge their activities, or leave applications too late, risk losing access to transitional relief and potentially being unable to operate in the UK once the regime goes live. Conversely, those that move early and engage seriously with the process could gain a competitive advantage as the market consolidates around authorised providers.
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