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.

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Initial viewProvisional assessment

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)

Cryptoasset Services (UK regime)

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.

  • ?

    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.

  • ?

    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?

Regulatory basis to examine

Your next steps

  1. 1Map every service to the new regulated cryptoasset activities
  2. 2Check whether you are currently MLR-registered and whether registration is still appropriate
  3. 3Decide whether to apply in the FCA’s application window, which closes on 28 February 2027
  4. 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
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This is an initial indication from published FCA material, not an FCA determination or legal advice.

Continue with a more detailed readiness assessment

If authorisation is required, check the firm’s governance, policies, resources and application preparedness.

Will the FCA Authorise Us?

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.

Want a consultant to look at your facts?

Book a free scoping call and we will map the permissions, evidence and timeline for your firm.