Digital Assets
Get authorised. Stay in the perimeter. Keep trading.
The UK is moving cryptoasset regulation from an anti-money-laundering registration regime to full authorisation under the Financial Services and Markets Act 2000. The FSMA 2000 (Cryptoassets) Regulations 2026 were made on 4 February 2026, and the substantive regime is expected to commence on 25 October 2027. The authorisation application window is expected to run from 30 September 2026 to 28 February 2027.
This is not a renewal. The FCA has confirmed there is no automatic conversion from MLR registration. Firms currently registered as cryptoasset exchange or custodian wallet providers must apply for full authorisation under Part 4A of FSMA, and meet the conduct, governance and operational standards that come with it. Firms that already hold other FSMA permissions will need to vary them via a VoP application before commencement.
There is a limited safety net. If a firm applies within the window but its application is not determined before the regime commences, a saving provision allows it to continue providing cryptoasset services until the application is finally determined. But that protection only runs to firms that apply in time — miss the window and you risk operating outside the perimeter.
On 30 June 2026 the FCA published the policy statements that finalise the core rulebook — PS26/9 to PS26/13 — covering admissions and disclosures and market abuse, stablecoin issuance, the regulated activities themselves, the prudential regime, and the application of the wider Handbook. The rules are now made; what remains is applying them to your business model.
Two of those chapters decide how you hold what belongs to your clients, and neither of them is CASS 15. CASS 16 governs UK stablecoin issuers: full backing from the point of minting, backing assets held on statutory trust with limits on intragroup custody, T+1 redemption, and a prohibition on paying interest or yield from the backing assets to holders. CASS 17 governs cryptoasset custodians — segregation, records and reconciliation of client cryptoassets, a technology-agnostic approach to private key management, and client money arising from safeguarding falling into CASS 7. Relevant specified investment cryptoassets are carved out of CASS 17 for now and stay within CASS 6, which makes classifying your assets the first question rather than a later one.
The firms that secure authorisation cleanly will be those that start their perimeter analysis and FCA engagement now. The FCA's perimeter guidance consultation (CP26/13, April 2026) is the natural starting point for that analysis. And from 11 May 2026, firms can request a free pre-application meeting through the FCA's Pre-Application Support Service, with meetings running from July 2026 — a genuine opportunity to test your thinking with the regulator before the formal window opens.
- Perimeter analysis: which of the new regulated cryptoasset activities you carry on, and which permissions you need
- Authorisation strategy and application support, including pre-application engagement with the FCA
- Recalibrating systems and controls designed for AML compliance to meet full FSMA expectations
- Token, stablecoin and tokenised-asset structuring within the regulated perimeter. Our Tokenised Assets Tracker follows who is tokenising funds, debt and real estate, and on what legal footing.
- Client assets: CASS 17 custody arrangements, and whether your assets fall into CASS 17 or remain in CASS 6
- Stablecoin issuance: CASS 16 backing, statutory trust, redemption and disclosure requirements
- Senior management and governance arrangements (SM&CR readiness)
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