FCA cryptoasset registration: what UK crypto firms need

What FCA registration under the Money Laundering Regulations asks of a UK crypto business, how crypto promotions are controlled, and what changes on 25 October 2027.

· Head of IT
· 7 min read
A gold pound coin and a violet glass bitcoin coin, with a small padlock and identity and check blocks

Since January 2020, a business that exchanges or holds cryptoassets for customers in the UK has needed to register with the Financial Conduct Authority (FCA). On 25 October 2027 that changes: crypto comes under the Financial Services and Markets Act 2000 (FSMA), and applications for the new FCA authorisation opened on 30 September 2026.

This guide is general information, not legal advice: the details depend on your services and your market, so confirm them with a lawyer and the regulator before applying.

What the activity is in law

Regulation 14A of the Money Laundering Regulations 2017 (MLRs) defines two businesses:

  • A cryptoasset exchange provider, including one that issued the coins, exchanges cryptoassets for money or for other cryptoassets, arranges or makes arrangements with a view to such exchanges, or operates a crypto ATM.

  • A custodian wallet provider safeguards cryptoassets, or private keys, for customers.

"Arranging" matters: a front end that never holds the coins can be in scope. Under regulation 56, neither may operate until it is on the FCA's register.

Who regulates it, and where

The FCA registers firms carrying on this business in the UK. An overseas firm whose only UK link is its clients is likely outside, though the promotion rules still reach it. E-money, payment and FSMA-authorised firms need it too.

The FCA's role is limited to anti-money laundering supervision; registration is not an endorsement. Where the Financial Ombudsman and the FSCS do not cover your customers, you must say so before you deal.

What registration asks for

The FCA sets out what it expects:

  • Capital. None is set: this is an anti-money laundering test, not a prudential one, though the business plan needs realistic financial information.

  • People and governance. A board member or senior manager responsible for MLR compliance, and a permanent money laundering reporting officer (MLRO) with crypto experience who is closely involved in the application. Officers, managers and beneficial owners must pass the fit and proper test; an unspent conviction listed in Schedule 3 fails it, and interviews are normally in person.

  • AML framework. Business-wide and customer risk assessments, policies, operational procedures, training, suspicious activity reporting and sanctions controls, tailored to your model. The FCA expects your tools to be chosen and configured before you apply, with the rules and thresholds for fiat and on-chain transaction monitoring. From 1 February 2027, correspondent relationships with crypto providers outside the UK need enhanced due diligence.

  • Travel rule. Under Part 7A, names and account numbers travel with transfers between crypto businesses; where a business outside the UK is involved, transfers of £800 or more (1,000 euros until 30 June 2026) also carry details such as an address.

  • Client funds and assets. An end-to-end flow of funds in fiat and crypto, naming every liquidity provider. Custody rules arrive with the new regime.

  • Local substance. The MLRO need not live in the UK, but the FCA looks carefully at one who does not.

  • Technology and outsourcing. Your key IT systems and security policies, and outsourcing contracts with service levels. You stay responsible, need full access to your data and should not let providers subcontract.

Steps and the FCA's timelines

  1. Talk to PASS first. Since 30 September 2026 the FCA steers new firms to FSMA authorisation; anyone still seeking registration should explain why to its free pre-application support service (PASS).

  2. Apply through the FCA's Connect system with final, signed-off documents. The fee is Category 6, £11,260 on the FCA's fees page on 6 October 2026.

  3. Assessment. The FCA must register you, or say it is minded to refuse, within 3 months of receiving the application, or the further information it asked for. In the first quarter of the FCA's 2026/27 year, the 9 registration cases it closed took a median of 236 days from receipt.

  4. Decision. Refusal comes by warning notice, then decision notice, which you can refer to the Upper Tribunal.

  5. After registration. An annual financial crime return within 60 business days of your accounting reference date, and FCA approval before anyone acquires control.

The FCA warns that applications made after 31 July 2027 are unlikely to be decided in time.

Why applications fail

At 1 September 2026 the FCA had determined 391 applications since January 2020: 68 registered, 263 withdrawn, 46 rejected and 14 refused. Rejection means the minimum information was missing. Firms withdraw when they cannot meet the standard at submission, need time to fill gaps, or expect refusal. Refusal follows a failed fit and proper test, false or misleading information, or reasonable grounds to suspect the firm will not meet its obligations.

The financial promotions regime

Since 8 October 2023, crypto promotions to UK consumers fall under section 21 FSMA, wherever the firm is based. There are four lawful routes: the promotion is communicated by an FCA-authorised firm; approved by one, which since 7 February 2024 needs approver permission; communicated by an MLR-registered crypto business under article 73ZA of the Financial Promotion Order; or covered by another exemption. A firm authorised only as an e-money or payment institution can neither communicate nor approve. Anything else is a criminal offence, punishable by up to 2 years in prison.

Promotions using the first three routes must follow PS23/6 and COBS 4.12A: a prescribed risk warning, no incentives to invest, a 24-hour cooling-off period the first time a consumer asks for a direct offer, client categorisation and an appropriateness test. Article 73ZA is removed when the new regime starts.

The new regime: made and proposed

The Cryptoassets Regulations 2026 create new regulated activities: issuing a qualifying stablecoin, safeguarding cryptoassets, operating a trading platform, dealing as principal or agent, arranging deals and staking. Each needs FSMA authorisation, and MLR registrations do not convert.

Status

What

When

Made

Cryptoassets Regulations 2026

Made 4 February 2026, in force 25 October 2027

Final

FCA rules, PS26/9 to PS26/13

30 June 2026

Final

PS26/18, perimeter guidance

16 September 2026

Open

Application period

30 September 2026 to 28 February 2027

Consulted

DP23/4 to CP26/13

6 November 2023 to 15 April 2026

Proposed

Draft amending regulations taking UK-issued stablecoins out of dealing and arranging

Laid in draft 15 September 2026, not yet made

Proposed

FCA consultations on firm failure and financial crime guidance

Promised for later in 2026

Under PS26/12, from 25 October 2027 own funds must meet the highest of a permanent minimum, a quarter of the previous year's relevant expenditure, and activity-based K-factors. The permanent minimum is £75,000 for dealing as agent or arranging, £150,000 for custody, a trading platform or staking, £350,000 for issuing a stablecoin and £750,000 for dealing as principal. The senior managers regime, the Consumer Duty and operational resilience rules apply, and the FCA expects a UK legal entity, with branches allowed only for some trading platforms.

The FCA expects to decide applications made in the window before 25 October 2027; a firm still waiting then can keep operating under a saving provision. A later applicant enters a transitional provision that only lets existing contracts run off, for up to two years. A firm that does not apply must wind down its UK business first.

Routes to launch before your own registration

The FCA describes a common model: a registered firm's exchange runs through an API or widget inside another firm's app. It works only if:

  • Your role stays outside "arranging". Under the new regime, solely introducing customers to an authorised firm falls outside one limb of arranging (article 9Z1), and the draft amending regulations would exclude purely technical access services.

  • Your promotions have a lawful route. The partner communicates them, they go out on its behalf as non-real-time content it prepared, or an approver approves them.

  • You pass your partner's checks. The FCA has warned registered firms about serving unregistered crypto firms that promote illegally to UK consumers.

Common mistakes

  • Generic policies, or AML tools still under evaluation when you apply.

  • An interim MLRO, or one who also runs sales.

  • Presenting an application or a registration as an FCA endorsement.

  • Assuming registration leads to authorisation: the FCA decides them separately.

  • Missing 28 February 2027 and losing the saving provision.

What this means for your platform

The FCA asks to see configuration: who is screened, which monitoring rules fire at which thresholds, how travel-rule data moves. Paynoramic's white-label crypto exchange platform ships with KYC/AML, compliance-reporting and custody modules that connect to providers such as Sumsub, Chainalysis, Notabene and Fireblocks, or to your own. The crypto card app adds cards from a licensed issuer. See also our MiCA checklist for the EU and our launch cost guide.

Sources

All checked on 6 October 2026.

Written by

Paynoramic's Head of IT

Head of IT

Head of IT at Paynoramic, responsible for the module library every platform is built from. Has worked on payment, banking and workforce platforms for companies including American Express, Teya and Indeed Flex, and for a global card issuer-processor. Writes about what a fintech or crypto launch needs beyond the software: licensing, certification and the real cost.

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