UK and EU crypto regimes: the road ahead in 2026

With Europe's cryptoasset framework now in operation and Britain's under development, differences in structure, territorial scope and regulatory mechanics are likely to shape compliance priorities in the coming months. Steven Lightstone and Hubert de Vauplane set out areas of convergence and divergence, along with preparatory steps for firms.

The regulatory direction of travel for cryptoassets became materially clearer in both the United Kingdom and the European Union during 2025. The year marked a transition point for both jurisdictions, albeit at different stages of maturity. In the EU, the Markets in Crypto-Assets Regulation (MiCA) entered its first full year of operation. In the UK, by contrast, 2025 was characterised by the completion of the core legislative framework for a new cryptoasset regime and the launch of consultations on the supervisory rules that will underpin it, with the regime now confirmed to take effect in October 2027.