UK Cryptoassets Regulated Activities Order 2025 Lays Foundation for Full Regulatory Regime

The United Kingdom Parliament received The Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025 ("the Cryptoassets Order") on December 15, 2025, when HM Treasury laid it before Parliament. The Order is final legislation — not a consultation or proposal — and its provisions come into force in stages beginning in 2027. The Cryptoassets Order extends the Financial Services and Markets Act 2000 regulated-activities regime to a defined set of cryptoasset activities for the first time.

The Cryptoassets Order brings the following activities within the FSMA 2000 regulated-activities regime: operating a cryptoasset trading platform, dealing in cryptoassets as principal or agent, arranging deals in cryptoassets, making arrangements with a view to transactions in cryptoassets, providing cryptoasset custody services, and communicating financial promotions related to cryptoassets. Any person carrying on a regulated cryptoasset activity in or from the United Kingdom must hold FCA authorisation unless an exemption applies. The FCA will set conduct-of-business rules for each regulated activity through separate consultations.

Crypto exchanges operating in or from the United Kingdom, custody providers, broker-dealers, and firms issuing financial promotions for cryptoassets must obtain FCA authorisation before the relevant provisions take effect in 2027. Firms currently registered with the FCA only under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 regime do not hold FSMA authorisation and must apply separately. Firms that fail to obtain authorisation before the relevant commencement date will commit a criminal offence under section 23 of FSMA 2000.

The Cryptoassets Order sets a staged commencement schedule, with individual provisions entering into force on dates to be specified by further statutory instrument or on a date set in the Order itself. HM Treasury has indicated that the FCA will issue conduct rules via consultation papers ahead of each commencement date, giving firms a defined window to seek authorisation. Firms should monitor FCA consultation papers issued after December 15, 2025 to track the specific dates and requirements for each regulated activity.

Source: HM Treasury, The Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025, laid before Parliament December 15, 2025. Policy note and draft Statutory Instrument: https://www.gov.uk/government/publications/regulatory-regime-for-cryptoassets-regulated-activities-draft-si-and-policy-note. Confirmed March 17, 2026.

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