🇫🇷 France vs 🇬🇧 United Kingdom: crypto licensing compared
Decision context and regulator route
France and United Kingdom are commonly considered side by side for crypto authorisation. In France the route is the MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. overseen by AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.; in United Kingdom it is the Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. under Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers.. The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
France: verified 2026-08-15 · United Kingdom: verified 2026-08-15
| Dimension |
🇫🇷 France
partly open
Verified 2026-08-15
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🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
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| Licence type | MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. |
| Regulator | AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | France capital requirement is included in the £349 pass. | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). |
| Timeline to authorisation | France timeline to authorisation is included in the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | France local substance is included in the £349 pass. | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. |
| Application cost | France application cost is included in the £349 pass. | FCA application fee GBP 11,260 (Category 6, fee-block G23, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | France ongoing cost is included in the £349 pass. | Annual FCA periodic fee under fee-block G.30 for 2026/27: minimum GBP 2,251 plus GBP 6.01 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. |
| Passporting | France passporting is included in the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | France mica casps approved is included in the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | France key restrictions is included in the £349 pass. | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. |
| Recent changes | France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026). | SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026 to 28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. The FCA published its 2026/27 fees policy statement PS26/14 on 2 Jul 2026; cryptoasset periodic fee-block detail is still expected in a September 2026 Handbook Notice, with nothing published early as of 15 Jul 2026. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026. |
| Difficulty rating | France difficulty rating is included in the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
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What changed recently
🇫🇷 France (verified 2026-08-15): France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026).
🇬🇧 United Kingdom (verified 2026-08-01): SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026 to 28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. The FCA published its 2026/27 fees policy statement PS26/14 on 2 Jul 2026; cryptoasset periodic fee-block detail is still expected in a September 2026 Handbook Notice, with nothing published early as of 15 Jul 2026. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026.
Quick answers
Who regulates crypto licensing in France and United Kingdom?
France: AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.. United Kingdom: Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers..
What licence do you need in France compared with United Kingdom?
In France the authorisation route is MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services.; in United Kingdom it is Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full France vs United Kingdom comparison?
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Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.