The United Kingdom operates outside MiCA following Brexit. Crypto-asset firms serving UK retail users are regulated by the Financial Conduct Authority (FCA) under a parallel framework that combines AML registration, financial-promotions rules, and a phased authorisation regime being rolled out through 2025-2027. UK retail crypto investors and EU CASPs targeting UK users need to understand the distinct requirements.
How does the UK FCA regulate crypto-asset firms in 2026?
The United Kingdom operates outside MiCA following Brexit. Crypto-asset firms serving UK retail users are regulated by the Financial Conduct Authority (FCA) under a parallel framework that combines AML registration, financial-promotions rules, and a phased authorisation regime being rolled out through 2025-2027. Framework: FSMA + Money Laundering Regulations 2017 (as amended) + Financial Promotions Rules. Scope: UK-resident retail crypto users + crypto-asset firms operating in or marketing to the UK. Key authority: Financial Conduct Authority (FCA), with HM Treasury policy oversight.
UK-resident retail crypto users + crypto-asset firms operating in or marketing to the UK
Key Authority
Financial Conduct Authority (FCA), with HM Treasury policy oversight
AML registration (current, mandatory)
Since January 2020, crypto-asset businesses operating in the UK must register with the FCA for anti-money-laundering supervision under the Money Laundering Regulations (MLRs). The FCA has rejected the majority of applications — the approval rate has been low and the bar is high. Firms operating without registration face criminal exposure.
Financial promotions regime (active since October 2023)
The FCA financial-promotions rules apply to all communications inviting UK consumers to engage with crypto investment products. Firms must either be FCA-authorised, partner with an authorised firm, or fall within a specific exemption. Non-compliant promotions trigger enforcement action and can be criminal. The rules cover both UK-based and overseas firms targeting UK consumers.
Full conduct authorisation (phased rollout 2025-2027)
HM Treasury has confirmed a phased introduction of full FCA conduct authorisation for crypto-asset firms, equivalent in scope to existing securities firm authorisation. The phasing covers stablecoin issuance first, then exchange/custody services, then broader activities. Implementation runs through 2027 with consultation rounds throughout.
Why UK is distinct from MiCA
MiCA passporting does not cover the UK. EU-MiCA-licensed CASPs cannot automatically serve UK users — they need either separate FCA authorisation or to operate under the financial-promotions partnership model. Conversely, UK FCA-registered firms cannot passport into the EU without separate MiCA authorisation. The two regimes are parallel rather than reciprocal.
What this means for UK retail users
UK users should look for FCA-registered firms (the FCA register is public). Promotions from non-registered firms targeting UK users are typically non-compliant. EU-MiCA-licensed CASPs serving UK customers should clarify their UK authorisation route. Pre-Brexit-era exchanges that operated under EU passporting must now establish a separate UK presence.
Full UK crypto-asset authorisation regime in force
FAQs
Can EU MiCA-licensed exchanges serve UK customers?
Not automatically. MiCA passporting covers EU + EEA only. UK service requires either FCA authorisation, an authorised partner, or a specific exemption under the financial-promotions rules. Several EU MiCA-licensed CASPs have either obtained UK FCA AML registration or have stepped back from UK retail marketing.
Is UK crypto tax different from German EStG §23?
Yes. UK crypto disposals trigger capital gains tax at either 10% or 20% depending on the user's overall income tax band. There is an annual CGT allowance (£3,000 from 2024-25) and no holding-period exemption. UK self-assessment requires reporting via the CGT pages of the SA return.
Does Brexit affect EU users using UK exchanges?
Yes. UK-based exchanges cannot passport services into the EU under MiCA. Most major UK-headquartered crypto firms have established EU subsidiaries (e.g., Coinbase Germany GmbH, Kraken Europe via Ireland) specifically to maintain EU market access post-Brexit and post-MiCA.
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