The UK: its own regime, live October 2027
Brexit took the UK outside MiCA. The current UK framework has two main parts: FCA anti-money-laundering registration for firms and the financial-promotions regime. The promotion rules make it unlawful to market cryptoassets to UK consumers unless the promotion comes from (or is approved by) an authorised firm.
The permanent regime is now law. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, made in February 2026, define the regulated crypto activities. They include operating a trading platform, dealing, custody, staking and qualifying stablecoin issuance. The FCA published final rules on 30 June 2026. Its authorisation gateway opens on 30 September 2026. The regime takes full effect on 25 October 2027. An EU MiCA entry gives no right to serve UK customers.
Switzerland: FINMA at home, EU subsidiaries abroad
Switzerland sits outside both the EU and the EEA, so MiCA cannot reach it and FINMA cannot grant MiCA authorisations. Domestically, Swiss providers operate under FINMA’s licensing framework and the 2021 DLT Act. Swiss firms that serve the EU market can use separately authorised EU or EEA subsidiaries.
In the ESMA snapshot dated 20 August 2026, Swiss crypto providers held MiCA authorisations through EU or EEA entities. The list includes Crypto Finance, AMINA, Relai, SwissBorg and Swissquote. RULEMATCH, Bitcoin Suisse and Sygnum complete the list. The last three use entities in Liechtenstein. A Liechtenstein entry can use the Article 65 notification route for other EEA states. We have not verified each host-state notification.
The narrow exception: reverse solicitation
Without a MiCA licence, a UK or Swiss platform may only serve EU clients who sought it out entirely on their own initiative. ESMA’s guidelines (February 2025) apply the exemption narrowly. Targeted advertising, an EU-language website, even app notifications reaching EU users can void it, and national regulators are instructed to actively monitor online activity. For a consumer the practical check is the contracting entity. If a non-EEA exchange markets to you, search for its EU or EEA entity in the CASP register and check the recorded service scope.
Practical checks for UK and Swiss platforms
- EU residents: UK and Swiss platforms without an EU entity cannot actively serve you. The venues that can are on the licensed list.
- UK residents: FCA rules determine your protections. The new UK regime takes full effect in October 2027.
- Firms: one licence does not cover both markets. A firm can use a MiCA entity for the EEA and separate FCA permissions for the UK. Compare capital and official fees on the licence cost page.
Common questions
Does MiCA apply to the UK?
No. MiCA is EU law and never applied in the UK after Brexit. UK crypto firms currently operate under FCA anti-money-laundering registration and the financial-promotions regime. The UK legislated its full authorisation regime in February 2026. It takes full effect on 25 October 2027.
Does MiCA apply to Switzerland?
No. Switzerland is outside the EU and the EEA, so MiCA does not apply there and FINMA cannot issue MiCA licences. Swiss providers operate under FINMA rules and the 2021 DLT Act. They can serve EU customers through a separate, authorised EU or EEA entity.
Can a UK or Swiss exchange serve EU customers without a MiCA licence?
Reverse solicitation can apply only when the client approaches the firm without any promotion from the firm. ESMA’s 2025 guidelines define this exemption narrowly. Targeted ads, EU-language websites or app notifications can disqualify the exemption.
Is a MiCA licence valid in the UK?
No. Passporting covers the 30 EEA states only. An EU-licensed exchange needs FCA-compliant financial promotions to target UK customers today. It will need UK authorisation when the new regime takes effect in October 2027. A UK licence gives no EU rights.
Page reviewed 2 September 2026. Sources: FSMA 2000 (Cryptoassets) Regulations 2026, FCA: new cryptoasset regime, Crypto Valley Journal: Swiss MiCA authorisations, ESMA reverse-solicitation guidelines. This page provides general information and does not provide legal advice.