FCA警告加密公司：新规下仅注册是不够的

Core Points

• Existing licenses will not be automatically transferred: Current registrations and licenses will not be automatically transferred to the new authorization system.
• Key dates for cryptocurrency companies: The application window opens on September 30, the deadline for applications for transitional arrangements is February 28, 2027, and the complete regulatory framework will officially take effect on October 25, 2027.
• International companies face compliance requirements: International operators, including U.S. companies serving UK customers, may need to obtain authorization from the UK Financial Conduct Authority (FCA).

The FCA issues comprehensive guidance to clarify the scope of crypto business regulation

On September 16, the UK's Financial Conduct Authority (FCA) issued a comprehensive guidance document detailing which cryptocurrency operating activities require authorization under the upcoming regulatory structure in the UK. The guidance clarifies how various types of cryptocurrency business activities will be defined and regulated when the UK's new regulatory framework is launched in October 2027.

The regulatory guidance covers a number of business activities, including issuing stablecoins, operating digital asset exchanges, engaging in cryptocurrency transactions, facilitating transactions, providing cryptoasset custody services, and managing pledge plans. Under FCA rules, companies cannot rely solely on their own business descriptions to determine compliance. Regulators will assess whether authorization is needed based on the functions and services actually provided by the company.

Existing licenses will not be automatically transferred to the new system

对于目前在英国运营的企业而言，一个关键考量点是：现有的FCA注册信息和监管许可不会自动迁移到新的授权框架中。在英国反洗钱法规下注册的企业也必须完成新的授权程序。这些现有的注册信息适用范围较窄，无法满足即将实施的监管框架要求。

持有不同监管授权的组织如果打算开展受监管的加密货币活动，可能需要申请修改其许可权限。FCA负责消费者、支付和竞争事务的执行总监David Geale表示：“为监管做准备始于理解这一框架如何影响您的运营。”

加密货币企业的关键时间节点

申请门户将于9月30日上线，为企业提供了超过一年的准备时间，以便在2027年10月25日监管框架正式实施前完成相关手续。然而，寻求过渡性安排的组织必须满足更早的截止日期，即2027年2月28日前提交申请。未能在此日期前提交可能导致失去享受过渡条款的资格。

After completing multiple rounds of industry consultations, FCA completed most of its regulatory packages in June this year. The Financial Services and Markets Act 2000 (Cryptographic Assets) Regulations 2026 were approved by Parliament in February this year. The finalized regulations cover stablecoin reserve requirements and redemptions, cryptocurrency custody standards, operational resilience expectations, consumer protection measures, and capital adequacy requirements. Additional legal rules regulate the token listing process and the prevention of misconduct on trading platforms.

The FCA plans to solicit feedback in October on stablecoins, proprietary trading operations, market-making activities and related modifications to certain technical service providers. The decentralized agreement framework and specific hosting structures will also be subject to further review.

Compliance requirements faced by international companies

U.S. companies serving UK customers or doing business in the UK market, whether or not they already have a U.S. license, may need to obtain authorization from the FCA. Regulatory approval obtained from the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC) or state authorities is not a substitute for the FCA authorization required to conduct regulated activities in the UK. The United States and the United Kingdom are following different timetables and separate legislative frameworks.

In September this year, the British House of Lords voted 194 to 138 to pass an amendment requiring the Treasury to publish a comprehensive national digital asset strategy within twelve months of the enactment of the Financial Services and Markets Act. In addition, the FCA and the Bank of England also plan to release a tokenization roadmap for wholesale financial markets before the end of the year.