Crypto Access

When does the new UK crypto regulatory regime start, and what activities will be regulated?

The UK’s future financial services regulatory regime for cryptoassets will come into force on 25 October 2027. From this date, firms carrying on newly defined regulated cryptoasset activities ‘in or to the UK’ will generally need to be authorised and supervised by the UK’s financial services regulator (FCA). The new rules constitute a full financial services regulatory regime that covers crypto business activities specifically, and supersedes the current AML-only FCA registration framework.

Practically, if your business model touches consumer crypto services involving exchange/trading, custody/safeguarding, stablecoin issuance, brokerage/intermediation, or other core crypto market infrastructure, you should plan now for how you ensure continued regulated access to the UK market.

Zumo is a specialist onshore provider of UK market access solutions and offers a number of supported access routes, ranging from full stack access harnessing Zumo licensing and compliance infrastructure through to strategic partnerships and targeted UK compliance and infrastructure support.

What is the FCA “crypto gateway” and when do we need to apply for FCA authorisation?

The FCA crypto gateway is the UK regulator’s timeline for getting crypto firms authorised under the incoming regulatory regime in October 2027.

If firms want to be guaranteed to be able to keep operating their UK crypto business, they need to apply between end September 2026 and end February 2027.

A firm that misses the end of February 2027 deadline but applies before the October 2027 go-live will be able to keep servicing existing clients but unable to take on any new business after October 2027 until the regulator has determined the application. The regulator will not expedite any late applications or give any assurance that applications will be determined before regime go-live.

A firm that has not applied at all by the go-live in October 2027 will need to run-off their UK business by that date.
Firms that have missed key application windows, or do not wish to submit a UK authorisation application in their own right, may seek instead to maintain UK market access via a future regulated UK partner. Get in touch to talk with Zumo about some of the continuing UK market access routes that are available based on the specifics of your business.

Do we need FCA crypto registration under the Money Laundering Regulations (MLRs) today—and will that be enough later?

As of today, businesses in the UK that provide certain defined cryptoasset services need to register with the FCA under the UK Money Laundering Regulations (MLRs).

With effect from October 2027, this transitions into a need to be fully regulated for the specific cryptoasset business activity you carry out (also referred to as ‘FSMA authorised’).

There is no automatic conversion from the current FCA MLRs crypto registration into future FSMA authorisation. Rather, firms will need to apply for authorisation at the gateway (see ‘FCA Crypto Gateway’ response above).

For firms considering UK market entry, MLRs registration can be viewed as today’s compliance baseline from which you build toward FSMA authorisation readiness.

Zumo is a specialist provider of UK market crypto solutions and can discuss with you the continuing regulated routes into the UK market.

How can crypto businesses access the UK consumer market—and what changes under the new regime?

Today, UK businesses are able to provide crypto services under MLRs registration (see ‘FCA crypto registration’ above), while non-UK businesses can gain lawful access to the UK market under an ‘S21 approver’ arrangement where promotions to UK consumers are reviewed and approved by an authorised UK firm.

As of October 2027 and the commencement of the incoming FSMA authorisation regime for cryptoasset activities, this ‘S21’ offshore marketing route comes to an end.

All businesses, whether in the UK or abroad, will need to either set up their own UK regulated crypto entity or identify a UK regulated partner route.

Zumo is able to offer a range of UK market access options for businesses looking to establish or continue their access to the UK crypto market.