The UK is entering a new chapter for crypto. A comprehensive regulatory regime is on the way, bringing large parts of the sector firmly inside the FCA’s perimeter and reshaping how many firms operate day to day.
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025, laid before Parliament in December 2025, marks the shift from a predominantly AML-led framework to full financial services regulation. The new regime is currently expected to take effect on 25 October 2027.
What will be regulated?
Once implemented, a broad range of activities will become regulated and will require FCA authorisation, including:
- issuing qualifying stablecoins
- safeguarding qualifying cryptoassets
- operating cryptoasset trading platforms
- dealing in cryptoassets (as agent or principal)
- arranging deals in cryptoassets
- cryptoasset lending and borrowing
- providing staking services
For firms currently registered under the Money Laundering Regulations, this is a significant step up. The expectation is a transition from AML registration to full FSMA authorisation.
The FCA’s message: “same risk, same regulatory outcome”
The FCA has been consistent in its underlying approach. Where crypto activities create similar risks to traditional financial services, firms should expect comparable regulatory outcomes. In practical terms, that means a higher bar on governance, controls and resilience.
Firms should plan for:
- SM&CR applying across the sector, with approvals for key individuals (including CEOs, executive directors, compliance officers and MLROs)
- stronger governance and accountability, including clear decision-making and oversight
- enhanced operational resilience (systems, continuity planning, and incident response)
- more demanding financial crime controls and ongoing monitoring
Consultations now in play
The FCA is already consulting on the detailed rulebook via three consultation papers:
- CP25/40 covers conduct and organisational requirements for trading platforms, intermediaries, lending, borrowing, staking and DeFi
- CP25/41 addresses admissions and disclosures, plus a new market abuse regime
- CP25/42 sets out prudential requirements
The consultation window closes on 12 February 2026, with final rules expected later in 2026.
What this means for your firm
For cryptoasset firms, the key advantage now is time. Early preparation will put you in a far stronger position, both to influence the outcome through consultation responses and to avoid a last-minute scramble for authorisation.
Priority actions typically include:
- reviewing the consultation papers and identifying pinch points for your business model
- considering whether to submit feedback, particularly where the proposals may have unintended consequences
- conducting a structured gap analysis against the proposed requirements
- mapping your authorisation pathway and planning application workstreams
- strengthening governance, SM&CR role mapping, and core control frameworks ahead of implementation
Leaman Crellin can support you at each stage, from consultation strategy and readiness planning through to authorisation, governance design, and implementation. If you would like to discuss what the regime means for your business in practical terms, please contact us.
