On 26 March 2026, the Financial Conduct Authority (FCA) published a new webpage for firms considering applying for registration under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) ahead of the start of the new regime for cryptoasset regulation. The FCA explained that this information is not relevant to cryptoasset firms that will still need to be registered under the MLRs but won’t require authorisation under the new regime set out in the Financial Services and Markets Act 2000 (FSMA 2000). This is because, for these firms. the MLRs gateway will continue to operate as normal.

Summary

The FCA set out the following information for firms:

  • Requirement to be registered under the MLRs: The FCA make clear that until the new FSMA 2000 regime starts, firms must continue to comply with the requirement to be registered with the FCA under the MLRs. However, under the new regime, firms carrying out regulated cryptoasset activities will need authorisation under FSMA 2000, which will apply to firms that are already registered under the MLRs.  Applications for authorisation under FSMA 2000 will open on 30 September 2026 and the new regime is expected to start on 25 October 2027. However, the FCA also sets out that it recognises that some new cryptoasset firms may want to start trading before the new regime begins and so may want to seek registration under the MLRs beforehand and that, as a result, firms may apply for registration at any time before the new regime begins 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 2026: The FCA explained that it will assess applications for registration submitted before the FSMA 2000 gateway opens as normal but that firms will still need to decide whether to apply for authorisation under FSMA 2000 once the gateway opens. If an application for registration has not been determined by this point, 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 2026: The FCA also set out that once the FSMA 2000 gateway opens, it will encourage firms to focus on securing authorisation under FSMA 2000, rather than applying for registration but that firms that still want to apply for registration after 30 September 2026 should contact the FCA’s pre-application support service to explain their plans and why they need registration.
  • Application forms, fees and outcomes: The FCA highlighted that where a firm can make a case for applying for registration after 30 September 2026  the FCA will accept the information contained in a firm’s application form for authorisation under FSMA 2000 as information relevant to its application for registration under the MLRs, where the firm confirms that it wants the FCA to do this, and, in such a case, the firm will pay a single application fee, which will be the higher of the fee for registration under the MLRs and the authorisation fee under FSMA 2000. 
  • 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, the FCA makes clear that, if a firm applies after 31 July 2027 it is unlikely to determine a firm’s application before the new regime starts, so firms should not apply for registration after this date.