FCA crypto consultation: key changes for UK firms before 2027

The UK’s approach to cryptoasset regulation continues to evolve, with the Financial Conduct Authority (FCA) launching a further consultation aimed at clarifying which crypto-related activities will fall within its regulatory perimeter.

As reported in recent coverage by GRIP and CoinGeek, the consultation represents another step towards the UK’s full crypto regulatory framework, expected to come into force in October 2027.

What is the FCA consulting on?

The FCA is seeking industry feedback on how it defines and regulates key cryptoasset activities, including:

• Issuing qualifying stablecoins;
• Safeguarding cryptoassets;
• Operating trading platforms;
• Dealing in cryptoassets (as principal or agent);
• Arranging transactions and staking activities.

The consultation is designed to help firms understand whether their activities will require authorisation under the upcoming regime and how the regulatory “perimeter” will apply in practice.

This builds on a series of prior consultations and legislative developments, including the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, which will formally bring crypto activities within the FCA’s remit.

A gradual path to regulation

The UK has taken a measured approach to crypto regulation compared to other jurisdictions, particularly the EU. Final rules are expected in 2026, with authorisation opening from September 2026 ahead of implementation in October 2027.

Comment from Gherson

Commenting in CoinGeek, Thomas Cattee, Partner and Head of White Collar Crime at Gherson, said:

“The introduction in the UK of a crypto regulatory regime is significantly lagging behind Europe, which is more advanced in introducing a fully enforced framework”.

He noted that the FCA’s latest consultation represents progress, describing it as “another slow step … in the long (seemingly endless) journey to a UK crypto regulatory regime”.

He also highlighted the importance of engagement with the consultation process, noting that recipients “would do well to engage and take heed” at this stage. He also expressed the hope that  “… more broadly the U.K. will (eventually) not get too far behind Europe in being seen as a place for crypto firms to do business”.

Why this matters for businesses

The consultation is not merely procedural, it has practical implications for a wide range of market participants, including:

• Cryptoasset firms;
• Financial institutions engaging with digital assets;
• Technology platforms facilitating trading or custody;
• Professional advisers, including law firms.

Firms must now begin assessing:

• Whether their activities fall within the FCA’s proposed definitions;
• Whether authorisation will be required;
• How compliance frameworks need to evolve ahead of 2027.

Failure to prepare early may expose businesses to regulatory risk once the regime is fully implemented.

Key takeaway

The FCA’s latest consultation confirms that the UK is moving closer to a comprehensive crypto regulatory framework, but the transition will be gradual.

For businesses operating in or entering the UK crypto market, early engagement with the consultation and proactive compliance planning will be critical.

How Gherson can help

Gherson’s White Collar Crime and Regulatory team advises businesses and individuals on navigating complex and evolving regulatory frameworks, including cryptoasset compliance and financial crime risk.

We can assist with:

• Assessing whether your activities fall within the FCA’s regulatory perimeter;
• Preparing for authorisation and regulatory engagement;
• Advising on financial crime risks linked to cryptoassets;
• Supporting compliance strategy ahead of the 2027 regime. 

Frequently asked questions

When will the UK crypto regime come into force?

The regime is expected to come into full effect in October 2027, with applications for authorisation opening in 2026.

What activities will require FCA authorisation?

Activities such as issuing stablecoins, operating trading platforms, safeguarding cryptoassets and facilitating transactions or staking are likely to fall within scope.

Why is the UK slower than other jurisdictions?

The UK has taken a cautious, consultation-led approach, aiming to learn from other jurisdictions before implementing a comprehensive framework.

What should firms do now?

Firms should review the consultation, assess their exposure and begin preparing for authorisation and compliance requirements.

Read more in the publications:

• FCA consults on guidance for future crypto activities authorisation in UK – GRIP
• UK FCA opens consultation on crypto scope – CoinGeek

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2026