What the FCA has published
The Financial Conduct Authority released a consultation paper on Wednesday setting out its interpretation of seven regulated cryptoasset activities: stablecoin issuance, trading platforms, dealing, custody, staking, and related intermediary functions. The document is intended to help firms determine whether they fall inside the regulatory perimeter before the UK's new crypto framework, introduced through the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 passed in February, comes into force.
The FCA described its substantive rule consultations — covering trading platforms, prudential standards, admissions and disclosures, and market abuse — as "substantively complete," with policy statements to follow this summer. The perimeter guidance consultation is a complement to that body of work, with its own final policy statement due in the autumn.
Timeline firms must plan around
The authorisation window opens September 30, 2026, and is expected to close in February 2027, giving firms roughly a five-month filing period before the regime becomes operative on October 25, 2027. Critically, existing registration under Money Laundering Regulations or payment frameworks does not carry over: all firms providing regulated cryptoasset services in the UK will need authorisation under the Financial Services and Markets Act.
Overseas operators serving UK users are equally in scope and will need to reassess their structures ahead of the 2026 window.
Structure and gaps in the framework
Yuriy Brisov, partner at Digital & Analogue Partners, described the FCA's approach to Decrypt as an "activity-based perimeter" built around intermediated models — issuers, custodians, venues, staking providers — rather than protocol-level functions. He characterised this as more flexible than entity-based licensing while aligning with current centralised-finance market structure.
However, Brisov noted that the perimeter as drafted "deliberately does not yet describe the part of the market most likely to define the next cycle," pointing to non-custodial and composable systems as areas where classification disputes will persist. The framework, he observed, largely repurposes the post-2008 regulatory toolkit — authorisation, prudential capital, conduct rules, market-abuse surveillance — without yet addressing risks that emerge from the technology itself, such as cross-protocol contagion or offshore spillovers.
The FCA has acknowledged the gap, confirming it will consult separately this year on DeFi, operational resilience for firms using distributed ledger technology, and updates to the Financial Crime Guide.
Industry reaction and competitive context
Not all practitioners view the pace positively. Thomas Cattee, white-collar crime partner at Gherson Solicitors, told The Block that the UK's crypto regulatory regime "is significantly lagging behind Europe, which is more advanced in introducing a fully enforced framework." Nick Jones, founder of payments platform Zumo, offered a more constructive reading, telling The Block that the FCA's phased roadmap delivers "a more systemic and predictable process than has been seen in many other jurisdictions."
The FCA's stated objective is an "open, sustainable and competitive" market in which UK consumers are served by authorised firms. How quickly the perimeter is extended to cover DeFi and novel custody models will determine whether that ambition translates into a framework fit for the market's next phase.
