The regulatory pipeline for UK financial services firms is fuller than it has been for a decade. Brexit created a divergence opportunity, the FCA has pursued its own reform agenda at pace, and several EU regimes continue to affect UK firms with EU-facing activity or EU group entities. The firms that navigate this well are those that get into preparation early — not those that wait for final rules before acting.
Below are the incoming changes with the most material implications for the firms we work with. Where exact dates are not yet confirmed, we indicate the expected window based on FCA and HMT publications.
Incoming regimes in detail
UK Crypto FSMA Authorisation Regime
The legislative framework is now confirmed. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 were made by Parliament on 4 February 2026 and bring cryptoassets within the FSMA regulatory perimeter. From 25 October 2027, no firm may carry out regulated cryptoasset activities in the UK without FCA authorisation. This is not a proposed change — it is enacted law.
The application window — 30 September 2026 to 28 February 2027 — is the only route for existing firms to secure transitional protection. Firms with applications submitted within this window can continue operating after October 2027 while the FCA determines their application. Firms that miss the window, or that have not applied by 28 February 2027, will need to cease regulated cryptoasset activities on 25 October 2027 with no transitional cover. The queue will be long and the FCA's assessment standards high. Applications submitted close to the deadline, or that are incomplete, risk not being determined in time.
The regulated activities are now defined in statute and include: operating a cryptoasset trading platform, dealing in cryptoassets as principal or agent, arranging deals in cryptoassets, safeguarding cryptoassets (custody), issuing qualifying stablecoins, and arranging cryptoasset staking. Each requires specific FCA permissions and fit and proper SMF holders. The FCA has consulted extensively across CP25/14 (stablecoins and custody), CP25/15 and CP25/42 (prudential), CP25/40 (trading platforms and intermediaries), CP25/41 (admissions, disclosures and market abuse), and CP26/13 (perimeter guidance, closes 3 June 2026). Final rules — the policy statements — have not yet been published but are expected before the application window opens in September.
AIFMD 2 — Delegation & Substance Requirements
AIFMD 2 introduces enhanced requirements around delegation arrangements, liquidity management tools (LMTs) and loan origination funds. For UK managers that delegate portfolio management from an EU AIFM, or that act as sub-adviser to an EU-authorised fund, the substance and oversight requirements are becoming significantly more demanding. The EU AIFM must be able to demonstrate it is genuinely managing the fund — not merely a letterbox entity.
UK MiFIR Review — Transaction Reporting & Transparency
The FCA's review of UK MiFIR is the most significant overhaul of transaction reporting since MiFID II. Key changes include: revised reportable fields, changes to the instrument reference data regime, consolidated tape (a single source of post-trade transparency data), and potential changes to the systematic internaliser regime. For firms with established transaction reporting infrastructure, this will require a material rebuild — not a patch.
T+1 Settlement — UK Equities
The UK is moving to T+1 settlement for equities in line with the US (which moved in May 2024) and ahead of Europe (which is targeting 2028). For trading firms, this compresses the operational window for trade matching, affirmation and settlement instruction — particularly for cross-border trades where T+1 in the UK but T+2 in Europe creates a mismatch.
UK Operational Resilience — DORA Equivalent
The FCA's existing operational resilience framework (PS21/3, effective since March 2022) already requires firms to identify important business services, set impact tolerances, and demonstrate they can remain within those tolerances. A UK DORA-equivalent consultation is expected to go further — particularly on third-party ICT risk management and incident reporting. Firms that have done the minimum under PS21/3 will face a meaningful step-up.
SMCR Reform — Phase 1 live, Phase 2 incoming
Phase 1 of the SMCR reform is now confirmed and partially in force. The FCA and PRA published PS26/6 and PS12/26 on 22 April 2026, implementing the first wave of reforms following the July 2025 consultations. The direction is simplification and proportionality — but the core architecture of individual accountability remains intact. The material question for most firms is not whether the regime is changing, but whether they have updated their procedures to reflect what has already changed.