🚨 The UK’s Financial Conduct Authority (FCA) is drawing a clearer line between crypto apps that simply transmit orders and platforms that actively decide how trades are executed.
Under draft guidance CP26/36, apps that select trading venues based on price, liquidity, cost or speed may need regulatory authorization. Changing orders, choosing execution times and evaluating counterparty risk could also indicate regulated involvement. Automation alone does not guarantee an exemption.
However, interfaces that merely transmit user instructions without influencing execution may qualify for a technical services exclusion, depending on the circumstances.
Existing UK crypto firms are expected to apply between September 30, 2026 and February 28, 2027, ahead of the new regime taking effect on October 25, 2027. The consultation closes November 18, 2026.
The bigger question is whether sophisticated trading tools can maintain their efficiency while meeting new compliance requirements.
For crypto platforms, execution technology is no longer just a product feature. It could become a regulatory responsibility.
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