FCA Cryptoasset Registration (MLR): Requirements, Fee and the Move to FSMA
FCA cryptoasset MLR registration: who must register, the £11,260 fee, the 3 month decision, why it does not convert and what registered firms must do now.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 19 October 2026.
The short answer
Cryptoasset exchange providers and custodian wallet providers must register with the FCA under the Money Laundering Regulations 2017 (MLRs) before they trade in the UK. Registration is an anti-money laundering gate, not a licence. The FCA applies a fit and proper test to the firm and its officers, managers and beneficial owners, and assesses its money laundering controls. The fee is £11,260 and the FCA must decide within 3 months of receiving a complete application.
Registration is being replaced. From 25 October 2027, the new regulated cryptoasset activities need FCA authorisation under FSMA, and MLR registration does not convert. The FCA application window for FSMA authorisation runs from 30 September 2026 to 28 February 2027, and the FCA now encourages firms to seek FSMA authorisation rather than registration.
Registered firms must do three things: apply for FSMA authorisation inside the window, plan for the end of the Article 73ZA promotions exemption at commencement, and, once authorised, notify the FCA under the new regulation 56B in place of registration. Firms not authorised by 25 October 2027 must rely on the saving or transitional provision, or exit.
Key facts at a glance
| Regulator | Financial Conduct Authority, as the anti-money laundering supervisor for cryptoasset businesses |
|---|---|
| Legal basis | MLRs 2017, regulations 14A (definitions), 54(1A) (register), 56 (requirement to register) and 58A (fit and proper test) |
| Who must register | Cryptoasset exchange providers and custodian wallet providers acting by way of business in the UK |
| Permission type | Registration, not authorisation. No prudential capital requirement |
| FCA fee | £11,260 (pricing category 6) |
| Decision period | 3 months from receiving the application form or any further information required |
| Latest sensible filing date | The FCA says firms should not apply for registration after 31 July 2027 |
| Converts to FSMA licence? | No. Registered firms must apply for FSMA authorisation |
| After 25 October 2027 | FSMA-authorised cryptoasset firms leave the register and notify the FCA under regulation 56B instead |
| Operating unregistered | A criminal offence under regulation 86, with up to two years' imprisonment on indictment |
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What is the FCA Cryptoasset AML Registration (MLR)?
FCA cryptoasset registration is the anti-money laundering registration that cryptoasset exchange providers and custodian wallet providers must hold under the Money Laundering Regulations 2017 before carrying on business in the UK. The FCA is the supervisor. It refuses registration unless the firm and each of its officers, managers and beneficial owners are fit and proper.
Registration is not a licence. It carries no capital requirement and no conduct or governance regime. Operating without it, when required, is a criminal offence under regulation 86 of the MLRs.
Registration is now in transition. From 25 October 2027, the new regulated cryptoasset activities under FSMA need FCA authorisation, and registration does not convert. Firms authorised under FSMA leave the MLR register and notify the FCA under regulation 56B instead.
Who needs FCA Cryptoasset AML Registration (MLR)?
Any firm or sole practitioner acting by way of business in the UK as a cryptoasset exchange provider or custodian wallet provider, until it holds FSMA authorisation for the new cryptoasset activities. Firms within the MLR definitions but outside the new FSMA activities continue to register after 25 October 2027.
- - Crypto exchanges, fiat to crypto and crypto to crypto
- - Brokers and OTC desks exchanging cryptoassets for customers
- - Crypto ATM operators in the UK
- - Custodian wallet providers holding cryptoassets or private keys for customers
- - Peer-to-peer platforms that arrange exchanges
- - Firms issuing their own cryptoassets while providing exchange services
- - FCA-authorised firms adding exchange or custody services
Crypto to crypto exchange is in scope: the regulation 14A definition covers exchanging one cryptoasset for another. Registration is not a route to the new licence: the FCA states there will be no automatic conversion. An overseas firm with no UK office and no UK agents is likely not carrying on business in the UK for MLR purposes, but that test is different from the FSMA regime, which captures overseas firms dealing directly with UK consumers.
Who must register under the MLRs?
Regulation 14A defines two types of business. A cryptoasset exchange provider exchanges, or arranges the exchange of, cryptoassets for money or for other cryptoassets, or operates a machine that does so automatically, such as a crypto ATM. It includes a firm acting as creator or issuer of the cryptoassets. A custodian wallet provider safeguards, or safeguards and administers, cryptoassets or private keys for customers.
Both must register with the FCA before they begin if they act by way of business in the UK. The FCA looks at whether the firm holds itself out as providing the service, gains a commercial benefit, how regular the activity is and whether it has a UK presence. A UK crypto ATM is always business in the UK. FCA-authorised firms providing these services must also register.
What the FCA assesses
- - Fit and proper test under regulation 58A for the firm and every officer, manager and beneficial owner. A conviction for an offence listed in Schedule 3 means automatic refusal
- - Skills, experience and probity of the people running the business
- - The risk that the business could be used for money laundering or terrorist financing
- - A business-wide risk assessment specific to the firm's products, customers, channels and geographies
- - Customer due diligence, enhanced due diligence and ongoing monitoring, including blockchain analytics
- - Travel Rule compliance: collecting, verifying and sharing originator and beneficiary information on cryptoasset transfers, in force since 1 September 2023
- - An appointed money laundering reporting officer (MLRO) under regulation 21(3)
How the application works
The firm applies through FCA Connect and pays the £11,260 fee on submission. The FCA expects every question answered, final signed-off documents rather than drafts, full disclosure and a declaration signed by the appropriate persons. Pre-application meetings are free and are requested through Connect.
The FCA must decide within 3 months of receiving the application form, or of receiving any further information it requires. A complete, specific application is the strongest way to keep to that timetable.
How registration transitions into the FSMA regime
SI 2026/102 creates new FSMA regulated activities from 25 October 2027 and amends the MLRs. After commencement, the FCA register under regulation 54(1A) covers only exchange providers and custodian wallet providers that are not FSMA-authorised cryptoasset firms. Authorised firms instead tell the FCA they act as an exchange or custody provider under new regulation 56B.
The MLRs' anti-money laundering duties continue to apply to the activity. What changes is the gate: FSMA authorisation, with its capital, conduct and governance rules, replaces registration for firms carrying on the new activities. Firms whose business falls within the MLR definitions but outside the new FSMA activities still register, and the MLR gateway continues to operate as normal for them.
| Scenario | Position on 25 October 2027 |
|---|---|
| Applied in the window and authorised | Operates under FSMA permission. Notifies the FCA under regulation 56B within 30 days of commencement |
| Applied in the window, decision pending | Saving provision: continues the business, including new business, until the decision is final |
| Applied after 28 February 2027, decision pending | Transitional provision: performs existing contracts only, no new contracts with new or existing UK customers |
| Application refused and no longer open to review | Transitional provision: orderly run-off over a maximum of two years |
| Did not apply | Must have run off UK business before commencement. Continuing risks breaching section 19 FSMA |
Applying for registration now
Since the FSMA gateway opened on 30 September 2026, the FCA encourages firms to focus on FSMA authorisation instead of registration. A firm that still needs registration first, for example to trade before October 2027, should contact the FCA Pre-application Support Service to explain why.
Where the FCA accepts that case, it can use the firm's FSMA application information for the registration too, and the firm pays one fee: the higher of the two. An MLR application form cannot be used as an FSMA application. The FCA says firms should not apply for registration after 31 July 2027, because a 3 month decision would then fall after the regime starts.
Financial promotions: what changes for registered firms
Today, an MLR-registered cryptoasset business can communicate its own cryptoasset promotions to UK consumers under the Article 73ZA exemption in the Financial Promotion Order, subject to the FCA promotion rules introduced in October 2023. SI 2026/102 removes Article 73ZA at commencement.
After 25 October 2027, a firm communicates its own promotions because it is FSMA-authorised. A firm that applied in the window and uses an s.21 approver may keep that approver until its application is decided.
What registered firms should do now
- - Map current services to the seven new FSMA activities and confirm the permissions needed
- - Apply for FSMA authorisation between 30 September 2026 and 28 February 2027 to keep the saving provision
- - Build the capital position: from £75,000 to £750,000 permanent minimum requirement depending on activity
- - Identify senior managers for SM&CR approval and prepare their applications
- - Upgrade from AML controls to a full compliance framework: Consumer Duty, CASS 17 custody, conduct, operational resilience and wind-down planning
- - Plan financial promotions for the end of Article 73ZA
- - Diarise the regulation 56B notification for the first 30 days after authorisation or commencement
MLR registration vs FSMA cryptoasset authorisation
| Point of difference | MLR registration | FSMA authorisation |
|---|---|---|
| Purpose | Anti-money laundering supervision | Full licence: prudential, conduct and governance |
| Who | Exchange providers and custodian wallet providers | Seven regulated activities from 25 October 2027 |
| Capital | None | £75,000 to £750,000 permanent minimum requirement |
| FCA fee | £11,260 | £2,820 to £28,150 by activity |
| Decision period | 3 months | 6 months from a complete application |
| People | Fit and proper test of officers, managers and beneficial owners | SM&CR approval of senior managers |
| Customer rules | AML duties and Travel Rule | Consumer Duty, COBS, CASS 17, Financial Ombudsman access, plus AML duties |
| Annual fees | Fee-block G30 | Fee-block A.26, charged on UK regulated income |
Firms authorised under FSMA move from fee-block G30 to A.26 and do not pay in both.
Key requirements
Fit and proper test
Under regulation 58A the firm and each officer, manager and beneficial owner must be fit and proper. A conviction for an offence listed in Schedule 3 means refusal. Otherwise the FCA considers compliance history, money laundering risk, and skills, experience and probity.
Money laundering reporting officer
The firm appoints an MLRO under regulation 21(3) with the authority, knowledge and time to run the anti-money laundering framework and report suspicions.
Risk assessment and controls
A documented business-wide risk assessment, customer due diligence, enhanced due diligence for higher-risk customers, ongoing monitoring and blockchain analytics proportionate to the firm's products and customers.
Travel Rule
Since 1 September 2023, firms collect, verify and share originator and beneficiary information on cryptoasset transfers, and take reasonable steps where the counterparty is in a jurisdiction without the rule.
Complete application
All questions answered, final signed-off documents, full disclosure, a declaration by the appropriate persons and the £11,260 fee, submitted through FCA Connect.
FSMA readiness
Registered firms should prepare for FSMA authorisation in parallel: capital from £75,000 to £750,000, SM&CR, Consumer Duty and CASS 17 custody rules, filed in the window ending 28 February 2027.
What does FCA cryptoasset registration cost?
The FCA registration fee is pricing category 6, currently £11,260, paid on submission. There is no prudential capital requirement. Registered firms pay annual fees in fee-block G30.
- - FCA application fee: £11,260
- - Combined route: where the FCA accepts a registration request alongside an FSMA application, one fee is paid, the higher of the two
- - Annual FCA fees in fee-block G30, moving to A.26 once FSMA-authorised
- - Third-party costs: blockchain analytics, Travel Rule messaging, screening and identity verification tools
- - Professional fees: we quote a fixed fee once the scope is confirmed
The application process
Confirm the route
We map the business to the MLR definitions and the new FSMA activities. Most firms now go straight to FSMA authorisation. Where registration is still needed first, we prepare the case for the FCA Pre-application Support Service.
Key person disclosures
We identify every officer, manager and beneficial owner and prepare full disclosures for the fit and proper test.
AML framework
We build the business-wide risk assessment, customer due diligence, monitoring, Travel Rule and reporting procedures specific to the firm's products, customers and corridors.
Business plan
We prepare the business plan and projections so they match the risk assessment and the controls described.
Submit through Connect
We file the complete application with final documents and the £11,260 fee, or a combined filing with the FSMA application where the FCA has agreed.
FCA assessment
We manage information requests. The FCA must decide within 3 months of receiving the application form or any further information required.
The FCA must decide within 3 months of receiving the application form or any further information it requires. The FCA says firms should not apply for registration after 31 July 2027, and registered firms should apply for FSMA authorisation by 28 February 2027.
How long does FCA cryptoasset registration take?
The FCA must decide within 3 months of receiving the application form, or of receiving any further information it requires. A complete application with final documents is the basis for a decision on that timetable.
For new firms the binding dates are now set by the FSMA regime. The FCA says firms should not apply for registration after 31 July 2027. FSMA applications filed by 28 February 2027 keep the right to trade under the saving provision if the FCA has not decided by 25 October 2027.
Why applications fail, and how we prevent it
Generic risk assessment
A risk assessment that does not describe the firm's own products, customer types, channels and corridors does not show the FCA how the controls fit the business.
Incomplete disclosure
The fit and proper test covers beneficial owners as well as directors. Missing or partial disclosure undermines the assessment of probity.
Draft documents
The FCA reviews only final, signed-off documents. Drafts and missing answers can lead to the application being rejected.
Treating registration as the end point
Registration does not convert to FSMA authorisation. A registered firm that does not apply in the window loses the protection of the saving provision.
Practitioner notes on registration and transition
- - Registration and authorisation run on separate tracks. The FCA decides each application separately, even if it assesses them together
- - Registration does not guarantee FSMA authorisation, and a refused registration does not prevent later authorisation if the firm meets the standard
- - Specific risk assessments win. Generic AML documents that do not name the firm's actual products, customers and corridors draw information requests
- - The fit and proper test covers beneficial owners as well as directors. Full disclosure at the start is essential
- - Promotions plans must change before commencement, because Article 73ZA ends on 25 October 2027
- - The regulation 56B notification is a new duty that is easy to miss in the first 30 days of the new regime
How we help
Registration or authorisation
We confirm the right route now the FSMA gateway is open and file the complete application, including the combined route where the FCA agrees.
AML framework
Risk assessment, customer due diligence, monitoring and Travel Rule procedures written for the firm's actual business.
FSMA transition
Capital, SM&CR, Consumer Duty and CASS 17 built for an application inside the window, plus the regulation 56B notification.
Regulatory Counsel obtains licences and runs compliance across 65+ jurisdictions. For UK cryptoasset businesses we handle MLR registration where it is still the right step and take registered firms through FSMA authorisation inside the FCA window. We answer every enquiry the same business day with a written proposal. We quote a fixed fee once the scope is confirmed.
Related licences
Frequently asked questions
Cryptoasset exchange providers and custodian wallet providers acting by way of business in the UK. That covers fiat to crypto and crypto to crypto exchange, crypto ATMs, firms issuing their own cryptoassets while exchanging them, and firms safeguarding cryptoassets or private keys for customers.
The FCA fee is £11,260 (pricing category 6), paid on submission. There is no capital requirement. Registered firms then pay annual fees in fee-block G30.
The FCA must decide within 3 months of receiving the application form, or of receiving any further information it requires. A complete application with final documents keeps to that timetable.
Yes, but since 30 September 2026 the FCA encourages firms to seek FSMA authorisation instead. Firms that still need registration should explain why to the FCA Pre-application Support Service. The FCA says not to apply after 31 July 2027.
No. The FCA states there will be no automatic conversion. Registered firms must apply for FSMA authorisation, ideally between 30 September 2026 and 28 February 2027.
FSMA-authorised cryptoasset firms leave the MLR register. They notify the FCA under regulation 56B that they act as an exchange or custody provider, within 30 days of commencement if already active. Firms outside the new FSMA activities continue to register under the MLRs.
Yes. Acting as a cryptoasset exchange provider or custodian wallet provider without registration breaches regulation 56 of the MLRs. Regulation 86 makes it a criminal offence, with up to two years' imprisonment on indictment.
Yes. Regulation 14A expressly covers exchanging one cryptoasset for another, and arranging such exchanges.
Whether the firm and each officer, manager and beneficial owner is fit and proper, the money laundering and terrorist financing risk of the business, and whether the anti-money laundering controls, including the Travel Rule, fit the firm's actual products and customers.
Yes, until 25 October 2027, under the Article 73ZA exemption and the FCA promotion rules. SI 2026/102 removes that exemption at commencement, so from then a firm needs FSMA authorisation, or an s.21 approver while its window application is pending.
Where the FCA accepts the case for registration after 30 September 2026, it can use the FSMA application information for both, and the firm pays one fee, the higher of the two. The FCA decides the two applications separately.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- FCA: Registration under the MLRs ahead of the new FSMA regime
- FCA: Who needs to register (cryptoasset businesses)
- FCA: How to apply for cryptoasset registration
- FCA: Authorisation and registration application fees
- Money Laundering Regulations 2017 (SI 2017/692)
- The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102)
- FCA: How the cryptoasset gateway will operate
- FCA: the transitional provision
- FCA: expectations for UK cryptoasset businesses complying with the Travel Rule
- FCA Handbook Notice 144: cryptoasset fees
Last reviewed by the Regulatory Counsel team on 19 October 2026.