MEMA Scope · Assessment
Do crypto exchanges and custodians need FCA authorisation?
A business lets customers buy, sell or exchange cryptoassets, holds cryptoassets for them, or provides related services such as staking. Review the initial view below and answer a few questions to refine it.
- Personalised to your business
- FCA rule references
- Follow-up questions available
Potential regulated activity identified
Cryptoasset services are expected to require FCA authorisation
Today, in-scope cryptoasset firms must be registered with the FCA under the Money Laundering Regulations. A new FSMA regime is expected to commence on 25 October 2027, with the FCA’s application window open from 30 September 2026 to 28 February 2027.
Route to consider: Direct authorisation (full permission)
Why this was flagged
- 1Exchanging, trading or holding cryptoassets for customers is within the scope of the UK’s new cryptoasset regime and the existing MLR registration requirement.
- 2Offering the service to UK customers brings the firm within UK rules even if it is based elsewhere.
Questions still to resolve
Answer to refine the view. The result updates as you go.
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Do customers always keep control of their own keys, with you never holding or controlling their cryptoassets?Non-custodial software can sit differently in the perimeter from custody.
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Do you offer staking, lending or yield on customers’ cryptoassets?
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Do you market to, or onboard, customers in the UK?
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Do you issue a stablecoin or token yourself?
Regulatory basis to examine
Your next steps
- 1Map every service to the new regulated cryptoasset activities
- 2Check whether you are currently MLR-registered and whether registration is still appropriate
- 3Decide whether to apply in the FCA’s application window, which closes on 28 February 2027
- 4Prepare custody, market abuse, disclosure, governance and financial crime controls
Where applications for this model most often fall short
- A custody and asset segregation design that can be evidenced
- Market abuse and trade surveillance controls
- A credible governance and senior manager structure for the UK entity
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.
About this business model
A business lets customers buy, sell or exchange cryptoassets, holds cryptoassets for them, or provides related services such as staking.
Today, in-scope cryptoasset firms must be registered with the FCA under the Money Laundering Regulations. A new FSMA regime is expected to commence on 25 October 2027, with the FCA’s application window open from 30 September 2026 to 28 February 2027.
This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.
Crypto exchange, trading platform or custodian: frequently asked questions
Do crypto exchanges need FCA authorisation in the UK?
Today, in-scope cryptoasset firms must be registered with the FCA under the Money Laundering Regulations. A new FSMA regime is expected to commence on 25 October 2027, and firms carrying on the new regulated cryptoasset activities will need FSMA authorisation.
When can crypto firms apply for FSMA authorisation?
The FCA’s application period started on 30 September 2026 and closes on 28 February 2027.
What could change the answer for crypto exchanges and custodians?
Today, in-scope cryptoasset firms must be registered with the FCA under the Money Laundering Regulations. A new FSMA regime is expected to commence on 25 October 2027, with the FCA’s application window open from 30 September 2026 to 28 February 2027. It can change depending on the answers to questions such as: Do customers always keep control of their own keys, with you never holding or controlling their cryptoassets? Do you offer staking, lending or yield on customers’ cryptoassets? Do you market to, or onboard, customers in the UK? Do you issue a stablecoin or token yourself?
Which FCA rules should crypto exchanges and custodians look at first?
Start with: FCA: a new regime for cryptoasset regulation; FCA: MLR registration ahead of the new regime; MLRs: cryptoasset exchange and custodian wallet providers; Restrictions on financial promotion. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for crypto exchanges and custodians?
Map every service to the new regulated cryptoasset activities. Check whether you are currently MLR-registered and whether registration is still appropriate. Decide whether to apply in the FCA’s application window, which closes on 28 February 2027. Prepare custody, market abuse, disclosure, governance and financial crime controls.
Businesses we check
MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.
Consumer credit
- Do car dealers offering finance need FCA authorisation?
- Do motor finance brokers need FCA authorisation?
- Do retailers offering buy now pay later need FCA authorisation?
- Do consumer lenders need FCA authorisation?
- Do debt collectors and debt administrators need FCA authorisation?
- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do open banking providers need FCA authorisation?
- Do money transfer and remittance businesses need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Mortgages
Investments and wealth
- Do financial advisers need FCA authorisation?
- Do discretionary investment managers need FCA authorisation?
- Do investment platforms and wealth-tech firms need FCA authorisation?
- Do crowdfunding and peer-to-peer lending platforms need FCA authorisation?
- Do corporate finance boutiques need FCA authorisation?
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
Want a consultant to look at your facts?
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Email: contact@memaconsultants.com