"The UK has finalised its crypto rules" is true and easy to misread. The FCA's rules are final. The regime is not live. As at 29 September 2026, the FCA's hold over a firm that runs a trading venue, holds client cryptoassets or issues a stablecoin still comes from anti-money-laundering registration and the financial promotions rules. The new authorisation requirement starts on 25 October 2027, and the window for applying opens at 7am on 30 September 2026.

This post sorts the pieces by who wrote them and how final they are: what is in force, what has been made but does not yet apply, and what is still a draft or a consultation. It describes published instruments and is not legal, tax or investment advice.

What is in force today

Three things already apply, and none of them is the new regime.

  • MLR registration (in force). Since January 2020, cryptoasset exchange providers and custodian wallet providers have had to register with the FCA under the Money Laundering Regulations 2017. This is a financial-crime registration, and the FCA says there will be no automatic conversion into authorisation.
  • The financial promotions regime (in force). Since October 2023, promotions for cryptoasset products and services must be fair, clear and not misleading. The Treasury made the amending order, SI 2023/612, on 7 June 2023, with most of it taking effect four months later.
  • Staking and collective investment schemes (in force). In January 2025 the government legislated to clarify that staking is not a collective investment scheme, according to the explanatory memorandum to the 2026 regulations.

Two layers: Treasury law and FCA rules

The regime is two things, made by two bodies, with different statuses.

HM Treasury: the statutory instrument

The Treasury decides which activities are regulated. Its route was: proposals in October 2023; confirmation on 21 November 2024 that it would proceed broadly in line with them; draft provisions on 29 April 2025; and final legislation laid in Parliament on 15 December 2025, all recorded on the Treasury's publication page. Both Houses approved the draft, and it was made on 4 February 2026 as SI 2026/102, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (made; mostly not yet in force).

The instrument creates six regulated activities: issuing a qualifying stablecoin, safeguarding qualifying cryptoassets, operating a cryptoasset trading platform, dealing as principal or agent, arranging deals, and staking. It also creates two designated-activity regimes, one for public offers and admissions to trading, the other for market abuse.

Lending and borrowing is not a separate activity. The Treasury's impact assessment says the dealing and arranging provisions are intended to capture it, and the FCA's PS26/11 says firms offering these services may be dealing as principal, dealing as agent or arranging. Whether a lending product needs authorisation therefore depends on how it is built, not on what it is called.

The FCA: rules and guidance

The FCA decides how authorised firms must behave. Its policy statement overview says it consulted across four discussion papers and ten consultation papers from 2023. Final material followed:

  • PS26/9 (30 June 2026, final): admissions and disclosures, and the market abuse regime. Retail-facing trading platforms act as gatekeepers: before a cryptoasset is admitted, they must do due diligence and ensure a disclosure document is published.
  • PS26/10 (30 June 2026, final): stablecoin issuance, covering backing assets, safeguarding and redemption. The redemption payment order is due by the end of the next business day, with the clock starting once the issuer has received the coin being redeemed.
  • PS26/11 (30 June 2026, final): trading platforms, dealing, arranging, lending and borrowing, staking and custody, with client-asset rules for custody in CASS 17 (see who actually holds institutional assets). Firms should check prices against at least three reliable UK authorised execution venues where possible, though they need not execute on those venues.
  • PS26/12 (30 June 2026, final): prudential rules. The capital coefficient for stablecoin issuance was cut from the consulted 2% to 1%.
  • PS26/13 (30 June 2026, final): how the wider FCA Handbook, including the Consumer Duty, applies.
  • PS26/18 (16 September 2026, final): perimeter guidance on when authorisation is needed, following CP26/13 in April 2026 and 78 responses.

"Final" needs a qualifier. The FCA says these rules apply to firms granted permission on or after 25 October 2027. Reading them as current obligations is the error.

The dates that matter

  • 4 February 2026: SI 2026/102 made. Under regulation 1(3), the provisions the FCA needs to make rules, and to receive and decide applications, took effect at the end of a 21-day period beginning the day after making, in late February 2026.
  • 30 June and 16 September 2026: final rules and perimeter guidance published.
  • 30 September 2026, 7am: the FCA's gateway opens.
  • 28 February 2027: the application period ends at 11:59pm under the FCA's direction of 20 February 2026, given under regulation 52 of SI 2026/102. The direction formally starts the period at 9am on 30 September 2026, while the FCA's gateway page says firms can apply from 7am. The period must be at least 28 days long and end at least 28 days before commencement, and the direction records the FCA's power to amend or replace it to extend the period.
  • 25 October 2027: the "full commencement day" in regulation 1(2). The instrument fixes the date; the FCA's overview page describes the regime as expected to come into force then.

Transitional arrangements

There is no automatic conversion. Firms registered under the MLRs, authorised under the Payment Services Regulations or Electronic Money Regulations, or relying on a section 21 promotions approver must obtain authorisation if their business falls within a new regulated activity, and firms already authorised for other activities must vary their permissions. The FCA's pages describe three paths.

  1. Applied within the window. The FCA says it expects to decide before commencement. If it has not, a saving provision lets the firm continue until final determination, including while a refusal is referred to the Upper Tribunal, although the FCA can in some circumstances direct the firm into the transitional provision instead.
  2. Applied late, or saw an application refused or withdrawn. An existing firm in this position enters a transitional provision at commencement. It may perform only pre-existing contracts, cannot sign new ones with existing or new UK customers, and has at most two years to run off. The FCA says it will not speed up a late application.
  3. Never applied. No protection. The firm must have run off its UK business before 25 October 2027, or risks breaching the general prohibition in section 19 of FSMA.

For firms considering MLR registration first, the FCA has a separate page. It will encourage firms to focus on FSMA authorisation once the gateway opens, and warns that an MLR application made after 31 July 2027 is unlikely to be decided before the new regime starts. Scope also reaches overseas firms: the Treasury's impact assessment says firms dealing directly or indirectly with a UK consumer will need authorisation whether they are based in the UK or abroad.

The Bank of England's separate regime

The FCA will regulate issuance, custody and admission to trading of UK-issued qualifying stablecoins. A stablecoin the Treasury recognises as systemic under the Banking Act 2009 would be regulated jointly by the Bank of England and the FCA. The Bank's publication of 22 June 2026 has two statuses in one document: it sets out the Bank's policy positions, while the draft Code of Practice that implements them was out for consultation until 22 September 2026, with finalisation intended by the end of 2026.

The positions include the following. In steady state, backing is 70% short-term UK government debt (residual maturity up to six months) and 30% unremunerated Bank deposits, revised from a 60/40 proposal, with issuers that are systemic at launch able to hold up to 95% in government debt as they scale. The November 2025 proposal for per-coin holding limits of £20,000 for individuals and £10 million for businesses is replaced by a temporary issuance guardrail of £40 billion per systemic stablecoin. Redemption is required in real time or within 24 hours on a rolling basis, with the clock starting once checks are done and the coins are received. The FCA's PS26/10 summarises the Bank's standard as "T+0".

Stablecoin economics are covered in our post on euro, sterling and Swiss franc stablecoins. Here the point is timing: none of this Bank code applies yet. The archived Paris 2026 programme (2–3 June 2026) included the panel "Beyond USD: The Future of Euro, Sterling and Swiss Franc Stablecoins" on the Hecto Main Stage on 3 June, from 14:00 to 14:40. Arnaud Caudoux, Elliot Hentov, Sasha Mills and Johannes Kern were on the panel, and Lisa Cameron moderated. It took place before the Bank's and the FCA's June publications, so anything said there predates the positions above.

What remains open

  • A second Treasury instrument, still a draft. The Financial Services and Markets Act 2000 (Cryptoassets) (Miscellaneous Amendments) Regulations 2026 were laid in draft on 15 September 2026, according to the Treasury, and need approval by both Houses; legislation.gov.uk listed them as not yet made as at 29 September 2026. Per the draft explanatory memorandum, they would take UK-issued qualifying stablecoins out of dealing and arranging, and out of safeguarding where the coins are held temporarily for a payment; keep lending and borrowing of those coins in scope; exclude institutional collateral and repo arrangements for all qualifying stablecoins; and add exemptions for some proprietary trading and market making. The FCA tells firms to consider the legislation as in force at the relevant time.
  • Payments reform. The Treasury's consultation on modernising payment services regulation, published on 14 July 2026, closes on 6 October 2026. According to the draft explanatory memorandum, it sets out the proposed approach to bringing certain stablecoins into the payments perimeter.
  • Bank of England finalisation. The Code of Practice is due by the end of 2026, with further consultations in 2027.
  • FCA work not yet done. In June the FCA said it would consult later in 2026 on the failure of stablecoin issuers and custodians, and on updates to its Financial Crime Guide; as at 29 September 2026 we found no published consultation on either. It will consult on DeFi guidance, where its rules apply if there is an identifiable controlling entity, and plans a further perimeter guidance consultation, which its 16 September 2026 press release dates to October 2026, aiming to publish that guidance in early 2027. Derivatives, distributed ledger technology and audit requirements are also on its list.
  • Throughput. The FCA expects to decide applications made within the window before commencement. Whether it can is the practical test of the timetable.

For how this compares with other jurisdictions, see what regulators actually permitted in 2026. For the European route, see MiCA CASP authorisation.