#UKAlgorithmicCryptoTradingAppsMayNee in #dFCAAuthorization FCA: your trading app's routing logic may now be a licensing question
The FCA's draft guidance CP26-36 says crypto apps may need authorization when an algorithm independently picks trading venues or execution routes for customers — based on price, liquidity, transaction cost or execution speed. That is potentially "arranging" cryptoasset transactions.
What the FCA counts as discretion:
Changing an order Deciding when- to execute it
Choosing a route based on counterparty risk or expected outcomes
Automation does not exempt developers or operators.
The narrow escape: interfaces that merely forward customer instructions without affecting execution may fall under a technology-services exemption.
Timeline:
Rules take effect 25 Oct 2027
Transitional applications open 30 Sep 2026 – 28 Feb 2027
Consultation closes 18 Nov 2026
Final guidance targeted Jan 2027 (document also references spring)
The tension: firms must decide on transitional protection while the rulebook is still in draft — and potential scope De reachesFi aggregators and automated interfaces, not just brokers.
#UKAlgorithmicCryptoTradingAppsMayNeedFCAAuthorization #dFCAAuthorization in line #CryptoRegulation
** onNote sourcing:** figures and dates above the news reports come from retrieved this session, not from the FCA's own published text — worth linking the consultation paper itself before publishing.
$IRYS
$NVDAB
The FCA's draft guidance CP26-36 says crypto apps may need authorization when an algorithm independently picks trading venues or execution routes for customers — based on price, liquidity, transaction cost or execution speed. That is potentially "arranging" cryptoasset transactions.
What the FCA counts as discretion:
Changing an order Deciding when- to execute it
Choosing a route based on counterparty risk or expected outcomes
Automation does not exempt developers or operators.
The narrow escape: interfaces that merely forward customer instructions without affecting execution may fall under a technology-services exemption.
Timeline:
Rules take effect 25 Oct 2027
Transitional applications open 30 Sep 2026 – 28 Feb 2027
Consultation closes 18 Nov 2026
Final guidance targeted Jan 2027 (document also references spring)
The tension: firms must decide on transitional protection while the rulebook is still in draft — and potential scope De reachesFi aggregators and automated interfaces, not just brokers.
#UKAlgorithmicCryptoTradingAppsMayNeedFCAAuthorization #dFCAAuthorization in line #CryptoRegulation
** onNote sourcing:** figures and dates above the news reports come from retrieved this session, not from the FCA's own published text — worth linking the consultation paper itself before publishing.
$IRYS
$NVDAB