UK crypto licence 2026 — FCA cryptoasset registration

Why UK crypto licensing matters for the operator base

The United Kingdom sits outside the EU's MiCA framework and runs its own crypto regime under the Financial Conduct Authority. UK-registered operators can serve the UK retail and institutional crypto market and work within London's financial-services ecosystem.

The UK is not in the EU or EEA, so UK crypto licensing gives no MiCA passport. Operators planning combined UK-and-EU operations need parallel licensing tracks rather than a single licence that covers both markets.

UK crypto licensing work in 2026 and 2027 covers two regimes at once: registration under the Money Laundering Regulations 2017, which still applies until the new regime starts, and FSMA authorisation under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, which comes into force on 25 October 2027. Of the 393 MLR registration applications the FCA determined between January 2020 and its 1 October 2026 data, 68 (17%) ended in registration.

Current FCA registration under the MLRs 2017

Since January 2020 the FCA has registered cryptoasset businesses under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Registration is required before a firm acts by way of business in the UK as a cryptoasset exchange provider (exchanging cryptoassets for money or for other cryptoassets, or operating crypto ATMs) or as a custodian wallet provider. Carrying on that business without registration breaches regulation 56 and is an offence under regulation 86.

The test is UK business, not UK incorporation or UK customers. A UK office or head office may indicate business carried on in the UK; the FCA says a firm with no UK office or activity beyond simply having a UK client is likely not carrying on business in the UK. A crypto ATM located in the UK always counts.

AML programme requirements are detailed. Customer due diligence, suspicious activity reporting, sanctions screening against Office of Financial Sanctions Implementation (OFSI) lists, transaction monitoring, customer risk assessment, source-of-funds and source-of-wealth checks, and politically-exposed-person screening all need to be documented and working. The FCA expects an MLRO with appropriate knowledge of UK regulation and experience, including knowledge of cryptoassets, and with authority and independence.

The FCA has 3 months from a complete application to decide, and the registration fee is FCA pricing Category 6 (£11,260). Practitioners report 9-15 months end-to-end once information requests are counted (practitioner estimate). In the 12 months covered by the FCA's 1 October 2026 data, 12 of 24 determined applications (50%) ended in registration, against 17% across the whole period since January 2020.

The FSMA cryptoasset regime from 25 October 2027

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) were made on 4 February 2026. Most provisions come into force on 25 October 2027; the provisions that let the FCA make rules, give directions and receive applications took effect 21 days after the Regulations were made. The Regulations create new regulated activities, including issuing qualifying stablecoins, safeguarding qualifying cryptoassets, operating a cryptoasset trading platform, dealing as principal or as agent, arranging deals and arranging staking, and set up admissions-and-disclosure and market abuse regimes.

The FCA published its final rules on 30 June 2026: PS26/9 (admissions and disclosures and market abuse), PS26/10 (stablecoin issuance), PS26/11 (regulated cryptoasset activities), PS26/12 (prudential regime) and PS26/13 (application of the FCA Handbook). Perimeter guidance followed in PS26/18 on 16 September 2026. Under PS26/12 a firm holds own funds at the highest of its permanent minimum requirement, its fixed overheads requirement and its K-factor requirement. The permanent minimum runs from £75,000 for dealing as agent or arranging to £750,000 for dealing as principal, with £350,000 for stablecoin issuance and £150,000 for safeguarding, trading platforms and staking. PS26/13 applies the Senior Managers and Certification Regime in full to authorised cryptoasset firms.

The FCA's authorisation gateway opened on 30 September 2026 and closes on 28 February 2027. The FCA has said it will determine applications made in that window before the regime starts; a firm still undecided on 25 October 2027 can continue under a saving provision. Existing MLR-registered firms must apply too, and the FCA states that MLR registration does not guarantee FSMA authorisation. Overseas firms undertaking cryptoasset activities in the UK must be authorised (PS26/12). Section 55V of FSMA gives the FCA 6 months to decide a complete application and 12 months at most for an incomplete one.

Financial promotions since 8 October 2023

Cryptoasset promotion rules have applied since 8 October 2023. A promotion to UK consumers must be communicated by an FCA-authorised person, approved by one, communicated by a cryptoasset business registered under the MLRs, or meet an exemption in the Financial Promotion Order. Promotions outside these routes breach section 21 of FSMA. Operators marketing into the UK from abroad need a lawful route before launch, not after authorisation.

How UK compares to EU CASP authorisation

UK FCA registration or authorisation and EU MiCA CASP authorisation serve different markets. The UK credential covers the UK only. A MiCA CASP authorisation can be passported across the EEA but gives no UK permission.

The substantive requirements partly overlap: both regimes look at presence, management, AML controls, fitness and propriety, and ongoing supervision. Procedure differs. MiCA requires a decision within 40 working days of a complete application (Article 63(9)); FSMA allows 6 months for a complete application. Supervisory practice also varies between EU member states.

Operators serving both UK and EU markets usually run two licensing tracks — FCA plus an EU or EEA CASP authorisation. The dual track adds compliance overhead but covers both markets. The choice of EU member state depends on the wider EU strategy.

Cost of UK crypto licensing engagement

Practitioners put a first-year FCA-registered build at £350,000-£750,000. Typical components, all practitioner estimates: UK entity and registered office (£5k-£15k), senior compliance hires (£200k-£400k loaded cost for an MLRO and a head of compliance), UK AML team (£100k-£200k), AML programme and documentation (£25k-£75k), FCA application legal fees (£75k-£200k), and supervisory engagement and remediation (£25k-£75k). FSMA authorisation adds the regulatory capital set by PS26/12.

Ongoing compliance budgets run £250k-£500k per year for a full FCA-registered operation (practitioner estimate): compliance team retention, transaction monitoring and sanctions screening tools, regulatory reporting, audited financial statements and ongoing legal advice.

The UK sits at the upper end of European cost levels. Where UK market access matters, the cost is usually part of the plan; operators minimising cost can obtain MiCA passport access more cheaply in some EU member states.

How to select UK crypto licensing counsel

Counsel choice matters because outcomes are uneven: of the 393 MLR applications the FCA determined between January 2020 and its 1 October 2026 data, 265 were withdrawn and 60 were rejected or refused. Practical selection criteria follow.

FCA track record matters. Counsel that has taken cryptoasset registrations through to a decision knows how the FCA runs information requests and where files run into difficulty.

Senior involvement matters. Fitness-and-propriety work, supervisory dialogue and enforcement defence depend on experienced partners leading the engagement rather than delegating it.

Cryptoasset specialism matters. Custody architecture, exchange operations, token classification and blockchain analytics all feed into the FCA file, and generalist financial-services teams without a cryptoasset practice can miss them.

Capacity for the FSMA gateway matters. With the window closing on 28 February 2027, counsel needs to run FSMA applications, including SM&CR arrangements and PS26/12 capital planning, alongside any MLR work, and to coordinate with EU CASP counsel for dual-track operators.