主要洞察：
- Crypto regulations will not create a standalone activity for lending or borrowing.
- The UK FCA says that lending may trigger the need for dealing, arranging, or custody permissions.
- Authorization applications open on September 30, before the regime starts in 2027.
The UK Financial Conduct Authority has clarified how 加密货币借贷 and borrowing fit into its incoming 监管框架 针对 数字资产. The regulator announced that neither activity will become a standalone regulated service under the new rules. Instead, businesses may trigger other crypto permissions depending on how they structure their transactions.
Such requirements can involve dealing, arranging deals, or safeguarding cryptoassets. This clarification arrives as the United Kingdom gets ready to open its authorization gateway on September 30, 2026. The broader framework governing crypto regulations is scheduled to take effect on October 25, 2027.
Crypto Regulations Map Lending Into Existing FCA Rules
Based on the FCA’s perimeter guidance, qualifying 加密货币借贷 and borrowing can encompass transactions that fall under other regulated activities. The regulator notes that these arrangements may resemble traditional loans while still amounting to cryptoasset deals.
Significantly, transferring cryptoassets in return for value can count as buying or selling under the rules. Another regulated transaction might be triggered by the reacquisition of the same or equivalent cryptoassets. Dealing requirements may also apply to yield paid in qualifying crypto assets.
Nonetheless, whether a company requires authorization will depend on the exact nature of its function within the arrangement. Permission requirements can differ for organizations acting as principals, agents, arrangers, or custodians. Consequently, the FCA evaluates the substance of each structure rather than depending solely on product labels.
The wider guidance also addresses qualifying stablecoin 发行 and cryptoasset trading platforms. It covers dealing in, arranging, and safeguarding cryptoassets, along with arranging qualifying cryptoasset staking. The FCA finalized its broader 加密货币规则 in June 2026 and published this latest perimeter guidance prior to the opening of applications.
In the meantime, the FCA stated that recent legal amendments introduce limited exclusions and additional clarity for certain technical service providers. The regulator intends to hold another consultation in October regarding targeted modifications to the perimeter guidance.
UK FCA Sets September Authorization Window
The authorization window will run from September 30, 2026, through February 28, 2027. Entities carrying out regulated crypto activities must obtain the appropriate FCA permissions prior to the full regime commencing.
The new framework officially launches on October 25, 2027, pursuant to the Financial Services and Markets Act 2000 Cryptoassets Regulations 2026. Current registrations do not automatically convert into authorizations.
As a result, companies already registered under anti-money laundering regulations may still need to apply for a fresh authorization. Firms that already hold FCA authorization might also need to vary their permissions if they incorporate regulated crypto activities.
Public consultation feedback featured contributions from Digital Asset, the Solana Research Institute, Circle, Fireblocks, 富兰克林邓普顿, BNY, and other industry participants.
To assist firms in preparing for the new rules, the FCA has provided pre-application discussions and webinars. David Geale, the FCA’s executive director for consumers, payments, and competition, remarked that the guidance assists companies in getting ready for authorization.
UK Banks Retain Control Over Crypto Payment Limits
In a separate development, UK retail banks will keep their discretion regarding payments linked to crypto exchanges after the new framework goes live. The FCA will not mandate that banks remove blanket restrictions on crypto-related transactions.
The Banker reported that nine out of the ten largest retail banks in the UK currently block or limit crypto payments. Such restrictions can include outright transaction bans or spending caps for transfers involving cryptocurrency platforms.
Even so, the FCA anticipates that extra regulatory safeguards will influence how banks evaluate crypto-related risks. The regulator has voiced hope that institutions might rethink broad restrictions as the new framework evolves.
Even with these expectations, banks maintain responsibility for their individual risk appetites and payment controls. The FCA has not imposed any mandate requiring lenders to process payments connected to crypto exchanges.
This banking stance operates alongside the wider rollout of crypto regulations rather than constituting a standalone authorization rule. Companies seeking approval from the FCA must still evaluate which regulated activities apply to their specific business models.
The FCA’s latest perimeter work likewise addresses technical services and staking arrangements. Government adjustments have delivered limited exclusions and further clarification for select providers, and the regulator will consult on those targeted areas in October.
This article is for informational purposes only and does not constitute financial, investment, or legal advice. Regulatory requirements can vary by business structure, and firms should seek professional advice where necessary.
常见问题
- Will 加密货币借贷 have a standalone regulatory category in the UK?
No, the FCA clarified that crypto lending and borrowing will not be treated as standalone regulated activities. Instead, they may trigger dealing, arranging, or custody permissions depending on the transaction structure. - When does the FCA authorization window open for crypto firms?
The authorization window runs from September 30, 2026, through February 28, 2027, ahead of the full regime launch on October 25, 2027. - Do existing anti-money laundering registrations automatically convert into authorizations?
No, existing registrations do not automatically convert, meaning firms may need to apply for fresh authorizations or vary their current permissions. - Are UK retail banks forced to lift their restrictions on crypto payments?
No, retail banks retain full discretion over their payment limits and risk appetites, and the FCA is not requiring them to process crypto-linked transactions.
