UK FCA Moves to Clarify: Crypto Apps That Select Trading Routes Based on Price, Liquidity and Other Factors May Need Authorization

October 24: The UK FCA's CP26/36 consultation paper, published on October 21, states that apps that evaluate and select or adjust trading routes based on price, liquidity, speed, cost and similar factors may not qualify for the "pure technical service" exemption. The key question is whether the service provider materially participates in trading decisions, not whether algorithms are used. Interfaces that process transactions solely according to user instructions and predetermined objective rules may still qualify for the exemption. This is currently a consultation stage, closing on November 18, and is not a new rule already in effect; the UK's new crypto regulatory regime will take effect on October 25, 2027.