Crypto registration in the UKOverview
Since January 2020, businesses carrying on cryptoasset exchange or custodian wallet activity in the UK have had to register with the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. That registration is an AML gateway only: it tests systems against financial crime and the fitness of owners and managers, but it does not grant permission to conduct regulated investment business. Since October 2023, the promotion of qualifying cryptoassets to UK consumers has also been subject to the financial promotions regime.
Parliament adopted the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 in February 2026, amending the Regulated Activities Order to create new regulated activities: issuing a qualifying stablecoin in the UK, safeguarding qualifying cryptoassets, operating a cryptoasset trading platform, dealing as principal or as agent, arranging deals, and arranging qualifying staking. The FCA completed its rulebook on 30 June 2026, including a dedicated prudential framework (PS26/12), conduct, admissions and disclosures, market abuse rules and a client-asset regime for stablecoin backing assets.
MLR registration does not convert automatically into authorisation. Every firm that intends to carry on a new regulated cryptoasset activity after 25 October 2027 must apply for Part 4A permission, or a variation of permission if it is already FSMA-authorised. Firms that apply within the gateway period benefit from a saving provision that allows them to continue serving customers while the FCA determines the application, including during any appeal. Firms that do not apply must run off their UK business before commencement.
For new entrants the practical choice is therefore between an MLR registration now, which remains required for AML purposes in the interim, and building the FSMA application from the outset. In most cases we recommend preparing both workstreams together, so that governance, financial resources and the compliance framework are designed once to the higher standard.
Key benefits
- Access to one of the deepest financial markets globally, with clear statutory rules once the regime commences
- A single FCA authorisation covering exchange, brokerage, custody, staking and stablecoin issuance activities
- Transitional protection for firms that file within the 30 September 2026 – 28 February 2027 window
- Strong regulatory standing that supports banking, payments and institutional counterparty relationships
- Clear prudential framework with activity-based capital floors rather than a one-size threshold
- Ability to combine crypto permissions with existing payments, e-money or investment permissions
Requirements
- A UK-incorporated entity or an appropriately established UK presence agreed with the FCA
- Fit and proper directors, senior managers and controllers, assessed under the threshold conditions
- Own funds meeting the higher of the permanent minimum requirement, fixed overheads requirement and activity-based K-factor requirements
- Liquid asset holdings meeting the basic liquid assets requirement
- AML/CFT framework covering customer due diligence, transaction monitoring, sanctions screening and the travel rule
- Segregation and safeguarding arrangements for client cryptoassets and, for stablecoin issuers, backing assets
- Operational resilience, cyber-security and outsourcing controls proportionate to the business
- Consumer Duty, financial promotions and complaints-handling arrangements for retail-facing services
- A credible business plan with three-year financial projections using the FCA financial data template
Licence options & capital
MLR registration
Required today for UK cryptoasset exchange and custodian wallet providers. Focuses on AML/CFT systems and fit and proper checks; it does not authorise regulated investment activity after October 2027.
Arranging deals or dealing as agent
£75,000 PMR
For brokers, introducers and agency execution models that do not hold principal risk.
Custody, trading platform or staking
£150,000 PMR
Applies to safeguarding qualifying cryptoassets, operating a cryptoasset trading platform and arranging qualifying staking.
Qualifying stablecoin issuance
£350,000 PMR
For issuers of UK qualifying stablecoins, with additional requirements on backing assets held under the new client-asset rules.
Dealing as principal
£750,000 PMR
For market-making and principal dealing models, which also attract net position and counterparty risk capital charges.
Step-by-step process
- 1
Perimeter analysis
Map each product and customer flow to the new regulated activities, exclusions and financial promotions rules, and decide whether a new application or a variation of permission is needed.
- 2
Pre-application engagement
Use the FCA's optional, free pre-application support service to test the business model and the permissions sought before filing.
- 3
Build the regulatory business plan
Prepare governance maps, financial projections, capital and liquidity calculations, wind-down planning and the policies the FCA expects to review.
- 4
Submit through FCA Connect
File the crypto application form and financial data template within the gateway window, ideally well before 28 February 2027.
- 5
Respond to FCA questions
Answer information requests and attend interviews with senior managers; the FCA has said late filings will not be expedited.
- 6
Authorisation and go-live
On approval, finalise capital, safeguarding and reporting arrangements and update customer documentation before 25 October 2027.
Typical documents
- FCA cryptoasset application form (new firm) or variation of permission form
- Regulatory business plan and three-year financial projections
- FCA financial data template and capital adequacy calculations
- Controller and close-link details with ownership structure chart
- Personal questionnaires, CVs and criminal record checks for directors and senior managers
- AML/CFT policies, business-wide risk assessment and travel rule procedures
- Safeguarding, custody and reconciliation procedures
- Operational resilience, IT security and outsourcing documentation
- Wind-down plan and liquidity risk assessment
- Consumer Duty assessment and financial promotions approval process
How Legal Wealth helps
Legal Wealth supports cryptoasset firms through both the current MLR registration and the FSMA authorisation gateway. We work with founders and boards to define the permissions they genuinely need, design a governance and capital model that the FCA can rely on, and prepare a coherent application file that reflects how the business actually operates. Our approach is compliance-first and discreet: we coordinate with your lawyers, auditors and technology providers, keep ownership and source-of-wealth information tightly controlled, and plan the timetable so that the business keeps its transitional protection. For principals, we can align the corporate structure with wider wealth, residence and succession planning.
Enquire with Legal WealthFrequently asked questions
Is my MLR registration enough after October 2027?
No. MLR registration does not convert into FSMA authorisation. Firms carrying on the new regulated activities must apply for Part 4A permission, ideally within the 30 September 2026 to 28 February 2027 window to benefit from transitional protection.
What happens if we apply after 28 February 2027?
Firms applying after the window but before commencement can still enter the transitional provision, but the FCA has said it will not expedite those assessments. Firms that have not applied by 25 October 2027 must stop the regulated activity.
How much capital do we need?
The permanent minimum ranges from £75,000 for arranging or agency dealing to £750,000 for dealing as principal, but the actual requirement is the highest of the PMR, the fixed overheads requirement and activity-based K-factors, so many firms will need more.
Can an overseas exchange serve UK customers?
Serving UK consumers will generally require authorisation once the regime commences. The FCA assesses the presence and controls needed case by case, and expects meaningful UK management and oversight.
How long does the FCA take?
There is no fixed determination period in the gateway guidance. The FCA aims to decide applications made in the window before commencement; in practice, file quality largely determines timing.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.