dfcaauthorization

#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The FCA's draft guidance CP26-36 says crypto apps may need authorization when an algorithm independently picks trading venues or execution routes for customers — based on price,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

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