Two crypto rulebooks reached a new stage within 48 hours of each other. On September 30 the UK’s Financial Conduct Authority began accepting authorisation applications from crypto firms, and on October 1 the US Securities and Exchange Commission proposed rules for how advisers and funds can custody crypto assets. One regulator is asking firms to apply. The other is asking the public to comment.
The UK moves from rules to applications
The FCA’s September 30 announcement says crypto firms can apply for authorisation from that day. For the first time, crypto firms operating in the UK will come under full FCA regulation, with standards covering consumer protection, safeguarding, market integrity and financial resilience. The FCA published its final crypto rules and guidance in June 2026.
Two dates frame the process. Firms that intend to keep operating in the UK should apply by February 28, 2027. The new regime comes into force on October 25, 2027. The FCA says it expects to decide applications submitted during the application period before the regime starts.
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Authorisation is not automatic. The FCA states that firms “will need to clearly demonstrate that they meet the FCA’s requirements,” and that firms unable to show the standards will not be authorised to operate in the UK market. Existing firms that apply inside the window can keep providing cryptoasset services, including taking on new business, while the FCA assesses them if no decision has been made by the time the regime starts. Firms that fail the assessment cannot continue offering regulated cryptoasset services.
Dominic Cashman, director of authorisation at the FCA, said: “The UK’s new crypto regime will give consumers greater protections and firms a clear framework to operate in. Firms can now apply for authorisation and start preparing for regulation.”
The scope was set two weeks earlier
The gateway followed a September 16 guidance release on which activities need authorisation. The FCA lists issuing qualifying stablecoins, operating cryptoasset trading platforms, dealing and arranging deals, safeguarding cryptoassets, and arranging cryptoasset staking. David Geale, executive director of consumers, payments and competition at the FCA, said: “This guidance gives firms the clarity they’ve asked for so they can prepare with confidence.”
The same release says the Government has introduced targeted legislative changes, including limited exclusions and clarifications for technical service providers, and that the FCA will consult in October on guidance updates that reflect them. The scope of the regime is therefore still being adjusted at the edges while applications are open. A firm deciding whether it needs authorisation has a live consultation to watch.
The US proposes a custody framework
The SEC’s October 1 release describes proposed rules and amendments that would give registered investment advisers and regulated funds, meaning registered investment companies and business development companies, a tailored framework for custodying crypto assets. The proposal sits under the Investment Advisers Act of 1940 and the Investment Company Act of 1940.
The SEC says the proposal would update requirements on financial statement audits for registered investment advisers and on broker-dealer custodial services for regulated funds. It would also permit crypto assets to be held in self-custody under certain circumstances and allow state trust companies to act as custodians for client and fund crypto assets. The public comment period stays open for 60 days after the proposing release appears in the Federal Register.
SEC Chairman Paul S. Atkins said in a statement quoted in the release: “Since the advent of Bitcoin in 2008, the crypto asset market has grown from a niche curiosity into a multi-trillion-dollar asset class to which investors actively seek exposure.”
What the two actions have in common
This section is our analysis, not a claim from either regulator. Both announcements deal with the same operational question: who holds the assets and what the holder has to prove. The FCA lists safeguarding of customer assets among the standards a firm must meet. The SEC proposal is built around custody, including which entities can hold crypto on behalf of advisers and funds. In both jurisdictions the custody function is being written into rules before the broader regime is complete.
The processes differ in stage. The UK has final rules, an open application window and a fixed start date. The US has a proposal, a comment period that has not yet begun counting, and no start date. A firm active in both markets is working to a deadline in one and watching a draft in the other.
The state level adds a third track. Our earlier coverage of the New York and Wyoming memorandum on digital asset oversight and of US and UK regulators writing crypto rules around custody covers the same direction from other angles. Because the SEC proposal would allow state trust companies as custodians, state supervisors are part of the federal custody picture rather than a separate one.
What it means for the finance leader
For a bank, asset manager or payments company with crypto exposure in the UK, the February 28, 2027 date is the working deadline. The FCA assesses applications against four named standards, and the FCA offers pre-application support meetings and on-demand webinars for firms preparing. The FCA says it expects to decide applications submitted in the window before the regime starts, so an earlier submission gives it more room to do that.
For a US adviser or fund sponsor, the proposal changes nothing yet, because proposals do not bind. It does show the topics the SEC has put on the table: when self-custody is permitted, whether state trust companies can serve as custodians, and how audit and broker-dealer custody requirements should change. The 60-day comment window starts only once the proposing release is published in the Federal Register, so the clock is not yet running.
What to do now
Three steps follow from the sources. First, map each crypto activity the firm performs against the FCA’s list of regulated activities and note any that depend on the October guidance consultation. Second, if the firm will apply in the UK, set an internal submission date well ahead of February 28, 2027. Third, if the firm advises on or manages crypto exposure in the US, read the SEC’s proposed rule and fact sheet and decide whether to comment before the window closes.
Neither regulator has announced how many applications or comments it expects, and neither release names any firm as an applicant. The facts that can be verified today are the dates, the standards and the proposed custody options.
