The FCA published this week its regulatory perimeter guidance for crypto firms, two weeks before authorization applications open on September 30. The deadline to submit applications closes on February 28, 2027, and the regime comes into force on October 25, 2027.
Territorial scope is one of the most relevant aspects of the FCA’s framework. Foreign firms operating with retail clients in the United Kingdom in crypto asset trading, brokerage or custody activities fall under British regulation, with no access to the overseas persons exclusion that typically applies in other contexts.
According to Gibson Dunn partner Michelle Kirschner, “if a firm wants direct access to UK retail clients, it needs to establish locally and obtain authorization.”
Submitting an application before the February deadline activates legal provisions that allow firms to continue operating while the FCA assesses their case. Those who miss that deadline could be prevented from onboarding new clients from October 2027 onwards. Shoosmiths partner Thomas Brown warned that firms should not treat February as a target date, but as a definitive deadline.
Source: https://www.fca.org.uk/news/press-releases/crypto-firms-get-guidance-how-new-regime-applies
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