In the UK: the new regime
Firms carrying on crypto-asset activities in the UK will need FCA authorisation under the new 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, and firms already operating that apply within it may be able to continue under the savings provisions while their application is decided.
Existing registrations do not convert automatically. A firm registered with the FCA under the Money Laundering Regulations today has to apply for authorisation like anyone else — and for firms already in the market, the application window is the date to plan to, not the commencement date.
In the EU: MiCA
Authorisation as a crypto-asset service provider under MiCA carries a passport across the EU. The transitional periods that let existing firms go on operating under national registrations ended on 1 July 2026, so a firm serving EU clients now needs a CASP authorisation. We prepare CASP applications, principally in Cyprus and Malta, and extensions of scope for firms already authorised.
What these applications turn on
Custody and client assets
Where the keys are held, who controls them, how clients' crypto-assets are kept apart from the firm's own, and how they come back to clients if the firm fails.
Market integrity and conflicts
How orders are handled, how conflicts of interest are identified and managed, and — for trading platforms — the operating rules and the surveillance that detects market abuse.
Financial crime and the travel rule
Transaction monitoring on-chain and off, sanctions screening, and the information that has to travel with every transfer. Regulators expect the controls to be built for crypto-assets, not adapted from a bank's.
Technology and resilience
ICT risk management, dependence on third parties, and incident handling — under DORA in the EU, and the FCA's systems and controls requirements in the UK.
Capital and the business plan
Minimum capital set by the services provided, and projections that show the firm will go on holding it. As in every regime, the numbers and the narrative have to agree.