Between 30 September 2026 and 28 February 2027 the UK runs a five-month application window, and many firms will discover that the permission they already hold is not the permission they need.
The Financial Conduct Authority has run a cryptoasset register since January 2020. Firms on it describe themselves, accurately enough, as FCA-registered. From 25 October 2027 a different regime applies: authorisation under the Financial Services and Markets Act, covering stablecoin issuance, custody, trading platforms, dealing, arranging and staking. The registration does not convert. An existing FSMA permission for other activities does not cover cryptoassets either. Firms that intend to serve the UK after commencement must apply through a gateway open from 30 September 2026 to 28 February 2027, and the date they file determines which of three outcomes they get: keep trading while the application is decided, service only pre-existing contracts, or run the book off.
Nothing about that is hidden. It is published, dated and unambiguous. And yet the marketing language of the industry will not change at all, because in that language a firm is simply “licensed in the UK”, before and after.
That phrase is the problem, and the UK is only the clearest current example of it.
The word covers five different things
We maintain a public comparison of crypto-asset licensing regimes in 50 jurisdictions, built from the operative instrument in each one. Sorted by what the regime legally is, the field splits like this: 16 jurisdictions run an authorisation, 13 issue a licence, 13 operate a registration, five combine a registration with a licence, and three have no dedicated regime at all.
In other words, in 13 of 50 places, the “licence” a firm advertises is an entry in a register. That is not a criticism of those regimes; a register entry with real AML supervision behind it is a legitimate instrument. It is a criticism of the vocabulary. A register entry and an authorisation impose different obligations, survive different transitions, and mean different things to a bank’s compliance team, but they arrive at the counterparty as the same word.
The other fields behave the same way. Nineteen of the 50 regimes set no fixed statutory minimum capital at all; where a floor exists it is usually tiered, most often at the EUR 50,000 that MiCA sets for its lightest class. Application timelines run from two months at the fast end to 24 months at the slow end. Retail access is permitted in 43 jurisdictions and limited in seven. None of that variation is visible in the sentence “we are licensed”.
Status does not travel, and it rarely says so out loud
The second failure mode is assuming that a status moves. It does not, in either of the two directions people expect.
It does not move between regimes inside one country. The UK case is the live one, but the European Union ran the same play with MiCA: a national VASP registration obtained before the regulation does not become a CASP authorisation. Lithuania, which had built one of the largest VASP registers in Europe, shows the gap most clearly: the register had been easy to join. The authorisation is not.
It does not move between regulators inside one market either. The United Arab Emirates has three: VARA in Dubai, the Financial Services Regulatory Authority in Abu Dhabi Global Market, and the Dubai Financial Services Authority in the DIFC. A permission from one of them is not a permission from another, and a firm that says it is “licensed in the UAE” has told you almost nothing about where it may actually operate.
The three questions
If the word is unreliable, the fix is not to stop using it. The fix is to treat it as a claim that resolves into three questions, all of them answerable from public sources in a few minutes.
What does the permission actually allow? Not the regime’s name, the permitted activities. Custody, dealing as principal, operating a trading platform and arranging deals are separate permissions in most modern frameworks, and a firm may hold one and not the others. Staking is the one that surprises people most often, because it was outside almost every perimeter until recently and is now inside several.
Who holds it? The licensed entity is frequently not the entity on the contract, the website or the invoice. Group structures are legitimate; silent substitution of one group company for another is where the protection quietly disappears.
From what date, and until when? A permission has a start date, sometimes an expiry, and increasingly a transitional shelf life. The UK’s saving provision runs until an application is finally determined. Belize’s special licences, once in force, must convert to full licences by 31 December 2027. A status that is true today can be scheduled to stop being true, and the schedule is usually published.
Why this is getting more important, not less
The regimes are converging on exactly this distinction. Europe replaced a patchwork of registrations with a single authorisation and a hard transition. The UK is doing the same thing on a published timetable. Oman is expected to replace an interim registration with a full framework. Belize has an end date on its transitional instrument. In each case the direction is from a low-threshold status that was easy to acquire towards a higher-threshold status that is not, and in each case there is a window in which both exist and sound identical.
For an operator, the practical consequence is that “we are licensed” has a shelf life and should be re-verified on the calendar, not on trust. For a bank, a payment partner or an institutional counterparty, it means that the licence question in an onboarding questionnaire is close to useless in its current form and can be replaced, at no cost, with three better ones.
And for the firms filing in London between 30 September and 28 February, it means the most expensive mistake available this quarter is not choosing the wrong jurisdiction. It is assuming that a status they already hold will carry them across a date that was published well in advance.
This analysis was prepared by Jagelski & Partners, which scopes licensing, company formation and banking routes for crypto, fintech and high-risk operators worldwide and publishes open comparisons of 50 licensing regimes: jagelski.com
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