Now it's the UK's turn ! The EU rolled out MiCA in December 2024, the US has been cooking its bills since January 2025

On 29 April 2025, the UK government published the draft Financial Services and Markets Act 2000 (Cryptoassets) Order 2025, marking a decisive shift in crypto regulation. Unlike the EU's MiCA framework, the UK has chosen to:

• Integrate cryptoassets directly into existing securities law rather than create a separate "light-touch" regime

• Apply the full spectrum of traditional financial regulation: capital requirements, conduct rules, market abuse provisions, disclosure obligations, and senior manager accountability

• Treat sterling stablecoins as securities rather than e-money or payment instruments

Impact on Previously Unregulated Crypto Players

Who's Affected The new regime captures virtually all crypto businesses operating in or serving UK customers:

• Crypto exchanges (both centralized and decentralized)

• Custodial wallet providers

• OTC brokers and market makers

• Staking service providers

• Stablecoin issuers

• Crypto lending/borrowing platforms

The Transformation Required

Previously unregulated players face a dramatic shift from simple AML registration to full FCA authorization, including:

• Capital Requirements (CRYPTOPRU)

• Senior Manager Accountability (SMCR)

• Consumer Duty compliance

• Market Abuse surveillance

• CASS-style custody rules

The Hard Choices Ahead

Unregulated players must decide quickly:

• Apply for Authorization (by Q4 2025)

• Exit UK Market

• Restructure Operations

We will have to weigh over expected consolidation, market exits, professionalization, higher barriers to entry, but potentially greater institutional confidence.

Critical Timeline

Late 2025: Application window opens

Q2 2026: Regime potentially goes live

T-Day + 6 months: Authorization deadline

The UK's approach rewards compliant, well-capitalized firms while essentially forcing out players unable or unwilling to meet institutional-grade standards.