UK FCA Cryptoasset Registration vs EU MiCA: Compared

Two different instruments, often confused

A founder shortlisting “the UK and the EU” for a crypto setup is, without realising it, comparing two different kinds of instrument. The EU side is MiCA — a comprehensive, purpose-built crypto regulation with a CASP authorisation that passports across 27 member states. The UK side is FCA cryptoasset registration — an anti-money-laundering supervision regime that sits in a single Schedule of the Money Laundering Regulations.

They are not the same depth, the same breadth, or even the same direction of travel. The honest comparison starts with that asymmetry.

What the UK regime is, today

The UK brought cryptoasset firms inside its anti-money-laundering perimeter on 10 January 2020, via an amendment to the Money Laundering Regulations 2017 (MLR 2017). From that date, two categories of firm have had to register with the Financial Conduct Authority (FCA) before operating in or from the UK:

• Cryptoasset exchange providers — firms exchanging cryptoassets for money or other cryptoassets
• Custodian wallet providers — firms holding cryptoassets on behalf of clients

Registration is AML-only. It requires fit-and-proper checks, an AML framework, and supervisory engagement — but it is not a full prudential or conduct licence. The FCA is explicit that registration does not give consumers the protections of FCA authorisation in the wider sense.

The other thing to be honest about: the approval profile is harsh. The FCA has reported, in its own public commentary on the regime, that a large share of cryptoasset registration applications are not approved — many are refused, many more withdrawn during the assessment when ownership structures, controls, or fit-and-proper issues do not stand up. The UK is not a fast, certain path.

What MiCA is, on the other side

MiCA — Regulation (EU) 2023/1114 — is what the UK regime is not: a comprehensive crypto regulation, applicable to crypto-asset service providers across the EU since 30 December 2024. A MiCA CASP authorisation covers capital, governance, conduct, client-asset safeguarding, complaints handling, market-abuse rules, white-paper obligations for tokens, and the rest of the rulebook. One authorisation, from one national competent authority, passports across all 27 EU member states under the EU passport mechanism.

For the rules behind that authorisation, see the crypto licensing pillar guide.

The comparison, side by side

Dimension	UK (FCA registration)	EU (MiCA CASP)
Regulator	Financial Conduct Authority	National competent authority in each member state
Legal basis	Money Laundering Regulations 2017 (MLR 2017)	Regulation (EU) 2023/1114 (MiCA)
Scope	Anti-money-laundering only	Comprehensive — capital, conduct, consumer protection
Entities in scope	Exchange providers and custodian wallet providers	All crypto-asset service providers (broad list)
Passport	No — the UK is not in the EU	Yes — across all 27 EU member states
Approval profile	Low — large share refused or withdrawn	Conditional on a complete, well-prepared file
Direction of travel	Fuller cryptoasset regime being phased in under FSMA 2023	Settled, with ongoing technical-standard build-out

The table makes the real point. On almost every column the two regimes are not parallel: the UK is narrower, the EU is broader, and only one of them comes with the EU single market attached.

The UK is moving — but slowly, and in pieces

The story does not end with MLR 2017. The Financial Services and Markets Act 2023 (FSMA 2023) gave the Treasury the legal powers to bring further cryptoasset activities — including stablecoin arrangements and certain trading activities — into the FCA’s full authorisation regime, beyond just the AML perimeter.

What FSMA 2023 did not do is switch the regime on. Implementation is being done in phases, with stablecoins and trading priorities moving ahead of a wider activity-based regime. A firm planning a UK setup in 2026 is therefore planning against a framework that is partly live and partly under construction — and that has to be reflected in scoping, not glossed over.

When the UK is the right answer — and when it is not

Strip the comparison down and it resolves on market access.

• A firm whose customers are in the EU needs a MiCA CASP authorisation in an EU member state. UK FCA registration does not reach that market. Switzerland’s experience is the same — see our Switzerland vs EU MiCA comparison.
• A firm whose customers are in the UK needs to satisfy the UK regime — currently FCA cryptoasset registration, with the broader authorisation regime arriving in phases.
• A firm targeting both is, as always, a two-licence project: a MiCA CASP authorisation for the EU plus the UK steps for the UK.

Working with counsel on the UK-versus-EU decision

The diagnostic for counsel: ask them to tie the recommendation to which market the firm actually serves, and to be explicit about what FCA cryptoasset registration is and is not — an AML registration with a low historical approval rate, not a comprehensive licence. Counsel that treats “FCA-registered” as a synonym for a UK crypto licence has overstated what the registration covers. For the EU side, see the crypto licensing pillar guide and the Crypto Jurisdiction Index. The firms in our index with UK and EU experience are listed below.