The UK now has a full licensing regime for crypto firms, and it comes with a deadline. The FCA started accepting applications for the new cryptoasset permissions at 9:00am on 30 September 2026. The application period closes at 11:59pm on 28 February 2027, and the regime starts on 25 October 2027. For a Turkish exchange or crypto asset service provider with UK retail users, the window matters more than the start date: applying inside it largely decides whether you can keep serving UK customers while the FCA decides, or must wind them down.
What the UK has legislated
The legal basis is the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), which HM Treasury made on 4 February 2026. Most provisions take effect on 25 October 2027 (the “full commencement day”); those letting the FCA make rules and accept applications are already in force. On 30 June 2026 the FCA published its final rules in policy statements PS26/9 to PS26/13, together with finalised guidance for international firms (FG26/7). Perimeter guidance followed in September 2026 (PS26/18). This is full FSMA authorisation, not a registration exercise.
Which activities need authorisation
The Regulations add a cryptoasset chapter to the Regulated Activities Order (RAO). A “qualifying cryptoasset” is fungible, transferable and more than a mere record of value or rights; e-money, fiat currency (including CBDCs) and closed-loop tokens are excluded (Art. 88F).
| Activity | RAO article | What it catches |
|---|---|---|
| Issuing qualifying stablecoin | Art. 9M | Offering a fiat-referenced stablecoin from a UK establishment, where redemption and the backing assets are also handled from the UK |
| Safeguarding (custody), and arranging safeguarding | Art. 9N | Having control of client cryptoassets, including holding all or part of the private keys |
| Operating a qualifying cryptoasset trading platform | Art. 9S | A system where multiple third-party buying and selling interests interact and result in contracts for crypto against money or other crypto |
| Dealing as principal | Art. 9T | Buying and selling on own account, for example holding out as willing to deal continuously at your own prices |
| Dealing as agent | Art. 9W | Buying or selling for clients as agent |
| Arranging deals | Art. 9Y | Bringing about trades, or making arrangements with a view to trades |
| Arranging qualifying cryptoasset staking | Art. 9Z6 | Making arrangements on behalf of others to use their crypto in blockchain validation |
There are exclusions (intra-group activity, introductions to authorised firms, temporary settlement), but a typical Turkish exchange with a matching engine, custodial wallets, instant buy/sell and staking touches four or five rows at once.
When a platform in Istanbul is treated as doing business in the UK
The decisive change is in section 418 FSMA (amended by reg. 41(6)). Under new section 418(6C), operating a trading platform, dealing as principal or agent, and arranging deals are deemed to be carried on in the UK when the firm is involved in the sale or subscription of a qualifying cryptoasset to or by a “consumer”, unless an FCA-authorised platform operator or principal dealer acts as intermediary between them. Under section 418(6E), safeguarding and staking for a consumer are deemed UK activities unless done at the direction of a UK-authorised firm. A “consumer” is an individual in the United Kingdom acting outside any trade, business or profession (s. 418(6F)). The FCA’s perimeter guidance (PERG 18) adds:
- No overseas persons exclusion. The Regulations do not apply the traditional overseas persons exclusion to the new activities.
- Institutional-only business. An overseas firm dealing only with UK institutional clients should not need authorisation. That changes if an institution acts for UK consumers as an agency broker outside a UK-authorised platform.
- The right intermediary. A UK firm that only arranges deals or deals as agent does not take you outside the perimeter.
- A territorial test. “Consumer” is not the Handbook’s client category; an individual treated as a professional client can still be one.
In practice, a Turkish exchange onboarding individuals in the United Kingdom through its own app is inside the regime from 25 October 2027, wherever its entity and servers sit.
UK subsidiary, branch, or neither
FG26/7 says the FCA expects a UK presence in all cases, with a UK legal entity as the baseline; a UK branch alone will generally not be enough. The exception is the trading platform: an overseas operator may be authorised through a UK branch where this gives UK clients access to its global liquidity, and the FCA’s example pairs that branch with a UK subsidiary handling activities such as custody. In the branch model the FCA authorises the whole firm, including its overseas offices, and expects the home regulator to have comparable protection and requirements “as determined by the FCA”; a letter of good standing alone is not sufficient. Otherwise custody and principal dealing are expected in a UK subsidiary, with an appropriate share of “mind and management” in the UK.
Two rules finalised in PS26/11 also shape group design. Orders for UK retail or elective professional clients must be executed on a UK-authorised execution venue. A firm dealing as principal for those clients must not systematically or predominantly source liquidity from a group platform that is not UK-authorised. A UK subsidiary that simply routes UK orders to the Istanbul order book will not work.
The application window: what applying by 28 February 2027 buys you
The FCA set the application period by a direction under regulation 52. Your position on 25 October 2027 depends on when you applied and what happened to the application:
| Your situation | Position on 25 October 2027 |
|---|---|
| Applied in the window; undecided, or refused but still open to review (e.g. at the Upper Tribunal) | Saving provision (reg. 53): continue until final determination; an overseas firm in the applicant’s group is covered too. FCA notification required; the FCA may in limited cases direct a refused applicant into the transitional provision instead (reg. 55(3)); ends two years after commencement |
| Applied in the window; finally refused or withdrawn | Transitional provision (regs. 55 and 56): run-off only, performing pre-existing contracts; no new contracts with existing or new UK customers |
| Applied after 28 February 2027, not authorised by 25 October 2027 | Transitional provision by operation of law; the FCA will not expedite late applications |
| Never applied, or application rejected as incomplete | No cover: run off UK business before 25 October 2027 or risk breaching s. 19 FSMA |
MLR-registered firms and firms relying on an s.21 approver do not convert automatically. The FCA advises applying as early as possible within the window.
Marketing to UK users today: the financial promotions regime
One UK regime already applies to Turkish platforms. Since 8 October 2023, qualifying cryptoassets have been within the UK financial promotion restriction (SI 2023/612). The FCA has said the rules apply to firms “wherever they are based globally”. A crypto promotion to UK consumers can lawfully go out through only four routes:
- an FCA-authorised firm communicates it;
- an FCA-authorised firm approves it (an “s.21 approver”);
- an MLR-registered crypto firm communicates it (FPO Art. 73ZA);
- it fits another Financial Promotion Order exemption.
Content rules include prominent risk warnings, a 24-hour cooling-off period and a ban on refer-a-friend bonuses. Non-compliant promotion may be a criminal offence (unlimited fine and/or up to two years’ imprisonment).
The FCA confirms that overseas firms that are neither authorised nor MLR-registered may use an s.21 approver. That route has an end date: a firm applying in the window may keep its approver until the application is decided, a late applicant only until 25 October 2027, and a firm that does not apply must run off its UK business before then. The Art. 73ZA exemption is repealed from full commencement (reg. 42(4)). The logic will be familiar from home, where the CMB has its own crypto advertising and campaign restrictions.
Four options for a Turkish platform
| Option | What it means | Watch out for |
|---|---|---|
| Exit | Offboard UK consumers, stop UK marketing | Run-off complete before 25 October 2027; no transitional cover |
| Restrict | Keep only UK institutional clients | Onboarding must exclude individuals; watch agency brokers |
| Authorise | UK subsidiary (plus, for the platform, possibly a UK branch), applied for in the window | UK substance, capital, execution venue rules |
| Partner | Reach UK consumers only via a UK-authorised platform or principal dealer | Marketing still needs a lawful route; liquidity routing to your group is restricted |
Whichever option you choose, the Turkish side runs in parallel. Under Article 35/B of Capital Markets Law No. 6362, added by Law No. 7518, a crypto asset service provider needs CMB permission to be established and to start operating in Türkiye, and nothing in the UK regime replaces that; our CASP licence application guide covers it step by step.
Where to start
Treat this as a board-level project with a fixed end date. Our CASP and crypto compliance team usually starts with these steps:
- Map UK exposure: individual users in the UK, volumes, custody balances, staking, UK-targeted marketing.
- Map each product to Articles 9N, 9S, 9T, 9W, 9Y and 9Z6 and test the exclusions.
- Choose exit, restrict, authorise or partner before year-end; if authorising, fix the entity structure early.
- Consider a free FCA pre-application meeting; requests without a meaningful analysis of activities are rejected.
- File a complete application well before 11:59pm (UK time) on 28 February 2027.
- Audit current UK promotions against the four lawful routes now.
Does our CMB permission let us serve UK users?
No. The UK regime turns on whether you serve consumers in the UK, not on your home licence. The home regulator matters mainly in the trading platform branch model, where the FCA expects comparable regulation “as determined by the FCA” and does not treat a letter of good standing alone as sufficient.
We have UK retail users but no UK company. Do we need FCA authorisation?
From 25 October 2027, yes, if you trade crypto with individuals in the UK or hold or stake it for them, unless an FCA-authorised platform or principal dealer is the intermediary (or, for custody and staking, you act at an authorised firm’s direction). There is no overseas persons exclusion.
What happens if we miss the 28 February 2027 deadline?
You can still apply before 25 October 2027, but the FCA will not expedite it. If you are not authorised by then, you enter the transitional provision: you may only perform existing contracts and cannot sign new contracts with existing or new UK customers.
Sources. Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, SI 2026/102 (made 4 February 2026): reg. 1 (commencement), reg. 40 (RAO Arts. 9M to 9Z6, 88F, 88G), reg. 41(6) (FSMA s. 418(6B) to (6F)), reg. 42(4) (omission of FPO Art. 73ZA), regs. 51 to 64 (Part 7, saving and transitional provisions); Financial Services and Markets Act 2000 (Financial Promotion) (Amendment) Order 2023, SI 2023/612, Art. 7 (FPO Art. 73ZA); FCA, Relevant application period direction (20 February 2026); FCA pages on the gateway, the transitional provision and s.21 approvers; FCA, cryptoasset regime policy statements (PS26/9 to PS26/13), PS26/11, PS26/18 (PERG 18) and FG26/7; FCA, press release of 7 September 2023 on crypto marketing rules; Law No. 7518 (Official Gazette No. 32590, 2 July 2024), adding Art. 35/B to Capital Markets Law No. 6362.
This article is general information and not legal advice; a specific situation should be assessed with counsel.
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