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Overseas crypto firms serving UK customers

Serving UK consumers from abroad needs FCA authorisation from October 2027.

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Reviewed by Harry Khan, Founder · 10 November 2026

An overseas firm that deals with, arranges deals for or runs a trading platform for UK consumers is treated as carrying on that activity in the UK. From 25 October 2027 it needs FCA authorisation or must stop dealing with UK consumers.

Who this is for

  • Overseas exchanges with UK retail customers
  • Overseas brokers and apps selling crypto to UK consumers
  • Global groups deciding between a UK branch and a UK subsidiary

What to do before 28 February 2027

  • Decide whether UK business is retail, institutional or both, which decides whether authorisation is needed
  • Choose the UK structure: a subsidiary, or a branch where the FCA accepts it for platform functions
  • Put UK-based senior management and controls in place
  • Apply in the window so you can rely on the saving provision

How we help

  1. ScopeWe confirm which of the seven activities your business carries on, and the capital and fee that follow.
  2. PrepareBusiness plan, financial projections, policies, wind-down plan and the individual forms for your senior managers.
  3. FileThe application submitted through the FCA’s Connect system inside the window.
  4. AnswerWe handle the FCA’s questions until it decides, then support the first year of compliance.

See also: Free readiness checker · Crypto compliance · Crypto licence consultants

Key dates

DateWhat happens
30 September 2026Authorisation window opens
28 February 2027Window closes
25 October 2027Regime starts; unauthorised firms that did not apply must have stopped UK business

Get in touch

Tell us where you are and where you want to be.

[email protected]
+44 7563 115980 (phone and WhatsApp)

Further detail

The UK consumer test

Dealing as principal or agent, arranging deals or operating a platform from outside the UK counts as UK activity where it involves a sale to a UK consumer. Dealings with UK institutional clients do not need authorisation unless the client is acting for UK consumers.

No overseas persons exclusion

The overseas persons exclusion, which lets some overseas firms deal with UK clients without authorisation, is not available for these cryptoasset activities.

Interposing an authorised firm

A UK consumer deal is not treated as UK activity if a firm authorised to deal as principal or to run a platform is interposed. Interposing a firm authorised only to deal as agent or to arrange does not have that effect.

Questions

Does an overseas exchange need FCA authorisation?

Yes, if it serves UK consumers after 25 October 2027. Otherwise it must stop dealing with them.

Can we use a UK branch?

The FCA accepts a branch model for trading platforms in suitable cases, assessed case by case against home-country supervision and protections. There is no formal equivalence.

Do UK institutional clients need us to be authorised?

Not unless the institution is acting as an intermediary for UK consumers.

Must the UK firm have UK-based managers?

Yes. The FCA expects the people who run the UK business to be based in the UK.

Sources

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