FCA issues guidance on crypto MLR registration ahead of full authorisation regime

The FCA has published guidance for firms considering applying for registration under the MLRs ahead of the new cryptoasset regulation regime coming into effect in October 2027.

The guidance highlights that until the new FSMA regime starts, firms providing in-scope cryptoasset services must register with the FCA under the MLRs. Under the new regime, those carrying out regulated cryptoasset activities will need authorisation under FSMA, including those that are already registered under the MLRs.

Applications for authorisation open on 30 September 2026, but the FCA recognises that some new firms may want to start trading before the new regime begins, and therefore may want to seek MLR registration in the interim.

The FCA noted that firms may apply for registration at any time before the new regime comes into effect, but should only do so if they are confident that they can be registered early enough for it to be worthwhile before the new regime begins.

In terms of timeframes, the FCA clarified that:

• Applications for MLR registration before 30 September 2026 (when the FSMA gateway opens) will be assessed as normal. If an application has not been determined by the gateway opening point, firms will still need to decide whether to apply for authorisation, as the FCA will determine the applications separately, even if they are assessed concurrently.
• Applications for MLR registration on or after 30 September 2026 will require firms to contact the FCA’s PASS team to explain their plans and why they require registration. From the gateway opening point, the FCA encourages firms to focus on securing FSMA authorisation rather than apply for registration.
• Applications for MLR registration after 31 July 2027 – the FCA’s deadline for determining applications for registration is 3 months from receipt of the application form or any further information required. Therefore, if a firm applies after this point, the FCA is unlikely to determine the application before the FSMA regime starts, so firms are advised not to apply for registration after this date.