Two regulators on opposite sides of the world chose the same date. September 30, 2026 is the first day of the UK Financial Conduct Authority’s application window for its new cryptoasset regime. It is also the last day of the no-action relief the Australian Securities and Investments Commission granted to digital asset firms.
Both deadlines follow the US Senate’s failure on September 15 to advance the CLARITY Act, which leaves US federal crypto law where it was. If your exchange, custody business or stablecoin has customers in these markets, your licensing plan for the next year depends on what you file in the next five months.
What Changes for UK Crypto Firms on September 30?
The FCA gateway runs from September 30, 2026 to February 28, 2027. The regime itself takes effect on October 25, 2027, when crypto activities move under the Financial Services and Markets Act 2000. On September 16, the FCA published final perimeter guidance naming the activities that need authorization: issuing qualifying stablecoins, operating a cryptoasset trading platform, dealing and arranging deals in cryptoassets, safeguarding, and arranging staking.
Firms registered with the FCA under the Money Laundering Regulations get no automatic conversion. A registered exchange applies for FSMA authorization on the same terms as a new entrant. It also has to meet FSMA standards on capital, governance and senior manager accountability.
For planning, February 28 is the date to work back from. Suppose you file inside the window and the FCA has not decided by October 25, 2027. The saving provisions then let you keep operating until it does. A firm that files in March 2027 loses that protection, and the FCA has said it will not fast-track late applications.
What Happens to Australian Crypto Firms After September 30?
ASIC’s sector-wide no-action position ends on September 30, 2026. It protects only firms that meet one of two conditions by that date. The first is lodging an application for an Australian Financial Services License or a variation of an existing one. The second is operating as an authorized representative of a licensee. From October 1, a firm that needs a license and falls outside those conditions risks breaching financial services law. The penalties are civil and criminal and include fines of up to 10% of annual turnover.
ASIC has recorded more than 45 license applications from digital asset businesses since it updated INFO 225 in October 2025. The Corporations Amendment (Digital Assets Framework) Act 2026 adds dedicated licensing for digital asset platforms and tokenized custody platforms from April 9, 2027. ASIC expects many of the authorizations firms hold today to remain necessary after that date.
Registration with AUSTRAC as a digital currency exchange runs on a separate track. It covers anti-money laundering obligations and gives no permission to provide financial products. A platform whose tokens or services count as financial products under INFO 225 needs both, and the September 30 deadline concerns the AFSL side only.
Where Does the CLARITY Act Failure Leave US Crypto Firms?
On September 15, the Senate voted 49-50 on cloture for the CLARITY Act, 11 votes short of the 60 needed to open floor debate. Senator Thom Tillis filed a motion to reconsider, which keeps the bill eligible for another vote.
The SEC continues on its own track. Its proposed Regulation Crypto Assets is open for comment until October 20, 2026. The proposal sets out an offering framework for token issuers and does not license exchanges, brokers or custodians. Until Congress passes a market structure law, a US crypto business works under the same stack as before. That means FinCEN MSB registration at the federal level and money transmitter licenses in the states that require them. If you paused US expansion to wait for a single federal license, you are back to planning state by state.
Can a Crypto License From Another Jurisdiction Replace UK or Australian Authorization?
No. Each regulator licenses activity aimed at its own market. A VASP registration in Georgia or a CASP authorization under MiCA does not let a firm onboard retail customers in the UK or Australia. Crypto promotions to UK consumers already have to come from, or be approved by, an FCA-authorized or FCA-registered firm. From October 2027, the new regime also covers overseas firms that serve UK retail customers directly.
An offshore crypto license does a different job. It fits a firm that decides to exit the UK or Australia instead of applying there. It also fits a firm that needs a licensed entity to open banking and payment relationships in the markets it keeps. The EU closed its own grace period on July 1, 2026, when the last MiCA transitional periods ran out, so that route also means full CASP authorization now.
If most of your revenue comes from UK or Australian customers, a license elsewhere will not protect it. The plan that works is to apply in that market, inside the window.
Equilex, a licensing consultancy for crypto and payment firms, advises clients to build their UK timeline around February 28, when the application window closes. The regime start in October 2027 matters less for planning, because the saving provisions depend on filing inside the window. In Australia, the equivalent date is September 30.
FAQs
Does FCA registration under the Money Laundering Regulations carry over to the new UK regime?
No. The FCA has confirmed there is no automatic conversion. Registered firms apply for authorization under FSMA. Filing between September 30, 2026 and February 28, 2027 gives access to the saving provisions if the FCA has not decided the application by October 25, 2027.
What happens if an Australian crypto firm misses the September 30 deadline?
From October 1, 2026, ASIC’s no-action position no longer covers a firm that needs an AFSL but has not lodged an application, varied an existing license or become an authorized representative. Such a firm risks breaching financial services law, with penalties that include fines of up to 10% of annual turnover.
What licenses does a US crypto business need while the CLARITY Act is stalled?
At the federal level, registration with FinCEN as a money services business. At the state level, money transmitter licenses in the states that require them. The September 15 cloture vote failed 49-50. Senator Tillis’s motion to reconsider keeps the bill eligible for another vote, and this two-level setup stays in place until a law passes.
About Equilex
Equilex is a licensing consultancy for crypto, payment and fintech companies. Its team prepares license applications and supports post-license compliance in more than 20 jurisdictions. These include FinCEN MSB registration in the US, AFSL and AUSTRAC registration in Australia, MiCA CASP authorization in Malta and VASP registration in Georgia.