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130 days until the UK application period closes (28 Feb 2027) · what changes

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Analysis

UK Crypto Firms Have Until 28 February 2027 to Apply. What Changes, and for Whom

MLR registration does not convert. 62 registered firms and every overseas exchange serving UK users must apply for FSMA authorisation; the paths explained with FCA sources.

The short version: from 25 Oct 2027, operating a crypto trading platform, dealing, arranging, safeguarding (custody), staking or lending in or to the UK needs FCA authorisation under FSMA. Today 62 firms hold the older anti-money-laundering registration and none holds the new authorisation, which cannot exist before the regime starts. Firms already serving UK customers have until 28 Feb 2027 to apply if they want to keep operating while the FCA decides.

UK crypto regime: the dates that matter2026-02-04 SI 2026/102 made; 2026-06-30 Final FCA rules; 2026-09-30 Applications open; 2027-02-28 Application period closes; 2027-07-31 MLR filing cut-off advised; 2027-10-25 Regime starts; 2029-10-25 Transitional run-off endsUK crypto regime: the dates that matter239 days between the application deadline and commencementToday4 Feb 2026SI 2026/102 made30 Jun 2026Final FCA rules30 Sep 2026Applications open28 Feb 2027Application period closes31 Jul 2027MLR filing cut-off advised25 Oct 2027Regime starts25 Oct 2029Transitional run-off endsSource: SI 2026/102; FCA. Run-off end = commencement + 2 years (max.). VASP Tracker
Key dates of the UK cryptoasset regime. Sources: SI 2026/102, FCA. Download: SVG · PNG · CC BY 4.0

What the Law Changes

The Treasury made the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) on 4 February 2026. Regulation 1(2) brings them fully into force on 25 Oct 2027, the “full commencement day”. Some parts started earlier so that the FCA could make rules and accept applications (reg. 1(3)). The FCA published its final rules and guidance on 30 June 2026 (policy statements).

Until then the only crypto-specific gate is registration under the Money Laundering Regulations (MLRs), required since 10 January 2020. It checks a firm's anti-money-laundering controls. It is not a licence, and the FCA says it does not give customers access to the Financial Ombudsman Service or the FSCS for cryptoasset activities (FCA).

MLR Registration Does Not Convert

The FCA is explicit: MLR-registered firms “will need to secure authorisation by us under FSMA” and there will be “no automatic conversion” (gateway page). Firms already authorised under FSMA for other business, such as e-money or investment firms, must apply to vary their permission instead. That covers every one of the 62 firms on today's register, from Coinbase and Kraken to Revolut and PayPal.

Three Paths for Firms Already Serving UK Customers

Three paths for firms already serving UK customersWhat happens on 25 October 2027. Applies 30 Sep 2026 – 28 Feb 2027 → Not decided by 25 Oct 2027 → Keeps operating, incl. new business, until decision | Applies after 28 Feb 2027 → Not authorised by 25 Oct 2027 → Existing contracts only, max. 2 years | Does not apply → No transitional relief → Must run off UK business before 25 Oct 2027Three paths for firms already serving UK customersWhat happens on 25 October 2027Firm with UK cryptobusiness todayApplies 30 Sep 2026 – 28Feb 2027Not decided by 25 Oct 2027Keeps operating, incl. newbusiness, until decisionApplies after 28 Feb 2027Not authorised by 25 Oct2027Existing contracts only,max. 2 yearsDoes not applyNo transitional reliefMust run off UK businessbefore 25 Oct 2027Source: FCA, How the gateway will operate; Transitional provision. VASP Tracker
Saving and transitional provisions. Sources: FCA gateway page, FCA transitional provision. Download: SVG · PNG · CC BY 4.0

Apply within the window (30 Sep 2026 – 28 Feb 2027). The FCA expects to decide these applications before 25 October 2027. If it has not, a saving provision in SI 2026/102 lets the firm keep providing services, including taking on new business, until the application is finally determined, including while a refusal is before the Upper Tribunal (FCA). In limited cases the FCA can direct a refused firm into the transitional provision instead.

Apply late (after 28 Feb 2027 but before 25 Oct 2027). The FCA says it will not speed up late applications. If one is still open on commencement day, the firm enters the transitional provision by operation of law: it may only perform contracts it already had, cannot sign new contracts with existing or new UK customers, and has at most two years to run off (FCA).

Do not apply. Firms with UK business in scope that never apply get no transitional provision. They must run off their UK business before 25 October 2027 or risk breaching the general prohibition in s.19 FSMA (FCA).

Overseas Exchanges That Rely on an s.21 Approver

Since October 2023, firms that are neither authorised nor MLR-registered may still promote crypto to UK consumers if an FCA-authorised “s.21 approver” signs off the promotions (PS23/6). Two of the most-used exchanges do this: Bybit (approved by Archax, according to its December 2025 launch release) and OKX (approved by Gateway 21, according to its UK website). Firms that apply within the window may keep using the approver until their application is decided; firms that do not apply before 25 October 2027 “must run-off their UK cryptoasset business before the new regime commences” (FCA).

What We Can and Cannot See

  • Applicants are not public. The FCA does not publish who has applied. We record a firm as having applied only when it says so publicly with a date, or when the FCA register shows a decision. On 21 Oct 2026 we had 0 such statements; 4 firms had said, or been reported as saying, that they will apply (table).
  • The register is the hard data. We read the FCA's list of registered and formerly registered cryptoasset firms (68 entries on 21 Oct 2026: 62 registered, 6 formerly registered) and will show FSMA authorisations as soon as they appear on the FCA Register.
  • Not legal advice. This page summarises FCA guidance and the regulations; the text of SI 2026/102 and the FCA Handbook prevail.

Sources

  1. SI 2026/102 www.legislation.gov.uk
  2. FCA: How the gateway will operate www.fca.org.uk
  3. FCA: Transitional provision www.fca.org.uk
  4. FCA: s.21 approvers www.fca.org.uk
  5. FCA policy statements www.fca.org.uk

Cite This Page

VASP Tracker, “UK crypto firms have until 28 February 2027 to apply. What changes, and for whom”, https://vasptracker.com/en/uk/analysis/fca-crypto-regime-what-changes-2027/ (accessed 21 Oct 2026). CC BY 4.0.

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