Crypto Trading Apps Require UK License, Application Period from September 30, 2026 to February 28, 2027

The UK's Financial Conduct Authority (FCA) has released draft guidance CP26-36, stating that crypto trading applications that select trading venues or execution paths for clients based on price, liquidity, cost, or execution speed must obtain authorization under new regulations, which will come into effect on October 25, 2027. Modifying trade instructions, deciding when to execute, or selecting routes based on counterparty risk and expected outcomes are all considered indicators of "discretionary participation." Automated decision-making does not exempt developers or operators, while interfaces that purely forward without affecting execution may qualify for a technical services exemption. Existing UK crypto firms must submit applications between September 30, 2026, and February 28, 2027, with the consultation period ending on November 18. The FCA plans to publish the final version in January 2027, with the consultation document indicating that the timeline is set for spring.

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