UK FCA webpage on registration under MLRs ahead of new crypto regime

The UK Financial Conduct Authority (FCA) has published a new webpage for cryptoasset firms who are considering applying for registration under the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), ahead of the new UK crypto regime which is due to come into force on 25 October 2027. The FCA states that the webpage is not relevant to cryptoasset firms that will still need to be registered with the FCA under the MLRs but will not require authorisation under the new Financial Services and Markets Act 2000 (FSMA) crypto regime, as for these firms, the MLR gateway will continue to operate as normal.

The webpage covers:

• The requirement to be registered under the MLRs: Firms who provide in-scope cryptoasset services in the UK are required to be MLR-registered before trading, until the new FSMA regime starts. Once the FSMA regime applies, firms carrying out regulated cryptoasset activities will require FSMA authorisation, including firms already registered under the MLRs. Applications for FSMA authorisation will open on 30 September. Firms may apply for registration at any time before the new regime begins on 25 October 2027. However, they should only do so if they are confident that they can be registered early enough for it to be worthwhile before the new regime starts.
• Applying for registration under the MLRs before 30 September: The FCA will assess applications for registration submitted before the FSMA gateway opens as normal. If an application for registration has not been determined by this point, firms will still need to decide whether to apply for authorisation under FSMA once the gateway opens. The FCA will determine the two applications separately, even if they are assessed concurrently.
• Applying for registration under the MLRs on or after 30 September: Once the FSMA gateway opens, the FCA will encourage firms to focus on securing authorisation under FSMA, rather than applying for registration. Firms that still want to apply for registration after 30 September are encouraged to contact the FCA's pre-application support service (PASS) to explain their plans and why they need registration.
  • Where a firm can justify applying for MLR registration after that date, the FCA will accept information submitted as part of a FSMA authorisation application as information relevant to its MLR registration application, subject to the firm confirming that it wishes the FCA to do so.
  • In these cases, a firm will pay a single application fee. This will be the higher of the MLR registration fee and the FSMA authorisation fee.
  • The FCA emphasises to firms that: (i) an application form for registration under the MLRs cannot be treated as an application form for authorisation under FSMA; (ii) MLR registration does not guarantee authorisation under FSMA; and (iii) if the FCA refuses a firm';s application for MLR registration, a firm may still be authorised under FSMA if it subsequently meets the required standards.
• Applying for registration under the MLRs after 31 July 2027: The FCA's deadline for determining applications for registration is three months from receiving the application form (or from receiving any further information required). Therefore, if a firm applies after 31 July 2027, the FCA is unlikely to determine the application before the new regime starts, so firms are advised not to apply for registration after this date.

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