Does MiCA apply in the UK or Switzerland?

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 an authorised firm makes or approves the promotion, a cryptoasset firm registered with the FCA for anti-money-laundering purposes makes it under article 73ZA of the Financial Promotion Order, or another exemption applies. The 73ZA exemption ends when the new regime takes full effect.

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 opened on 30 September 2026, and firms can apply until 28 February 2027 for the transitional arrangements. The regime takes full effect on 25 October 2027. An EU MiCA entry gives no right to serve UK customers.

1. February 2026

   Cryptoassets Regulations 2026 made

   The regulations define the regulated crypto activities.
2. 30 June 2026

   FCA publishes final rules

3. 30 September 2026

   FCA authorisation gateway opened

4. 25 October 2027

   The regime takes full effect

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 DLT Act, in force since 2021. Swiss firms that serve the EU market can use separately authorised EU or EEA subsidiaries.

In the ESMA snapshot dated 6 October 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, a website in a local EU language that is not customary in international finance, or push notifications for other products can void it, and national regulators should closely 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