Your trading algorithm may be doing more than executing orders. That distinction could determine whether its provider needs regulatory approval in the UK. 👀

On October 21, the UK Financial Conduct Authority (FCA) opened a consultation on draft guidance explaining which crypto businesses may require authorization under the incoming regulatory regime.

Apps that automatically select trading venues or execution routes based on price, liquidity, cost or speed could fall within rules covering the arrangement of crypto transactions. By contrast, software that simply transmits customer instructions without influencing execution may qualify for a technical-services exemption.

My take: This is an important development for DeFi aggregators, automated trading platforms and crypto software developers. Automation alone does not guarantee exemption from regulation. Businesses will need to examine how their algorithms make decisions and whether their services actually facilitate transactions. Clearer rules could strengthen consumer protection, but uncertainty over licensing could also increase compliance costs and slow some innovations.

The new regime is scheduled to take effect on October 25, 2027, while consultation responses are due by November 18, 2026.

Should algorithmic crypto apps face the same regulatory scrutiny as traditional financial intermediaries?

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