Crypto on-ramps and off-ramps
A business that exchanges crypto-assets for fiat currency operates under several regulatory regimes at once. We structure and prepare the authorisations it requires, across the EU, the UK and the UAE.
At a glance
- Key dates
-
- 2 March 2026PSD2 authorisation for e-money token services
- 1 July 2026MiCA transitional periods ended
- 30 September 2026FCA application window opens
- 28 February 2027FCA application window closes
- 25 October 2027UK regime expected to come into force
- Authorisations
- MiCA CASP authorisation
Payment institutions and EMIs
Investment firms and MTFs
The licensing structure
An on-ramp or off-ramp typically combines up to three regulated functions. Each is authorised under a different regime, and the applications must describe a single, consistent business.
Crypto-asset services
Exchange of crypto-assets for funds or for other crypto-assets, custody and administration, transfer services and execution of orders.
CASP authorisationFiat payments and e-money
Receiving and paying out client funds, accounts and cards, and transfers of e-money tokens that qualify as payment services.
Payment institution or EMIDerivatives and trading venues
Perpetual futures and other crypto derivatives, and the multilateral trading facilities on which they are traded.
Investment firm or MTFClient funds
Under MiCA, a crypto-asset service provider must place clients' funds, other than e-money tokens, with a credit institution or a central bank by the end of the business day following receipt, in an account separately identifiable from its own. A CASP may provide payment services related to its crypto-asset services only where it, or a third party it uses, is authorised under the Payment Services Directive.
E-money tokens
Transfers and custody of e-money tokens on behalf of clients can qualify as payment services. In June 2025 the European Banking Authority advised national regulators to require authorisation under the Payment Services Directive from 2 March 2026 for CASPs providing such services. A CASP that transfers or holds e-money tokens for clients therefore requires its own payment or electronic money licence, or an arrangement with an authorised provider.
Structuring the group
Single jurisdiction
CASP and electronic money institution authorisations held by group entities in the same member state, with shared governance, systems and compliance functions.
Authorised partner
CASP authorisation, with fiat payments and e-money token transfers provided under contract by an authorised payment or electronic money institution.
Phased approach
CASP authorisation first, supported by an authorised partner, followed by the group's own payment or electronic money licence as volumes grow.
The appropriate structure depends on the firm's customers, volumes, banking relationships and target markets. We advise on the structure before any application is prepared.
Derivatives and perpetual futures
Crypto derivatives, including perpetual futures, are generally financial instruments under MiFID II and fall outside MiCA. Offering them requires authorisation as an investment firm, and operating a venue on which they are traded requires authorisation to operate a multilateral trading facility. In February 2026 ESMA stated that perpetual futures offering leveraged exposure to crypto-assets are likely to fall within the national product intervention measures on CFDs. See investment firms and MTFs.
United Kingdom
Crypto-asset exchange services will require FCA authorisation under the new crypto-asset regime, which is expected to come into force on 25 October 2027. The FCA's application window runs from 30 September 2026 to 28 February 2027. Fiat payment services require authorisation as a payment or electronic money institution. The sale of cryptoasset derivatives to retail clients is prohibited in the UK.
United Arab Emirates
Virtual asset activities in Dubai, outside the Dubai International Financial Centre, are regulated by VARA. The DFSA and the FSRA regulate crypto-asset activities in the Dubai International Financial Centre and Abu Dhabi Global Market respectively, and the Central Bank of the UAE licenses retail payment services onshore.